Joint Petition

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UNITED STATES OF AMERICA
BEFORE THE
FEDERAL ENERGY REGULATORY COMMISSION

North American Electric Reliability Corporation

)
)

Docket No. _______

JOINT PETITION OF THE
NORTH AMERICAN ELECTRIC RELIABILITY CORPORATION AND
WESTERN ELECTRICITY COORDINATING COUNCIL FOR APPROVAL OF
RETIREMENT OF REGIONAL RELIABILITY STANDARD BAL-002-WECC-3
Chris Albrecht
Assistant General Counsel
Western Electricity Coordinating Council
155 North 400 West, Suite 200
Salt Lake City, UT 84103
(801) 582-0353
[email protected]
Counsel for the Western Electricity
Coordinating Council

Lauren Perotti
Assistant General Counsel
Alain Rigaud
Associate Counsel
North American Electric Reliability
Corporation
1401 H Street NW, Suite 410
Washington, D.C. 20005
202-400-3000
[email protected]
[email protected]
Counsel for the North American Electric
Reliability Corporation

February 27, 2026

TABLE OF CONTENTS
I.

SUMMARY ............................................................................................................................ 2

II.

NOTICES AND COMMUNICATIONS ................................................................................ 5

III. BACKGROUND .................................................................................................................... 5
a.

Regulatory Framework ....................................................................................................... 5

b.

WECC Reliability Standards Development Procedure....................................................... 7

c.

Procedural History of BAL-002-WECC-3 ......................................................................... 7

d.

Development of the Proposed Retirement of the Regional Reliability Standard ............... 8

IV. JUSTIFICATION FOR RETIREMENT .............................................................................. 10

V.

a.

Retirement of Requirement R1 ......................................................................................... 11

b.

Requirement R2 ................................................................................................................ 12

c.

Retirement of Requirements R3 and R4 ........................................................................... 13
EFFECTIVE DATE .............................................................................................................. 15

VI. CONCLUSION ..................................................................................................................... 16

Exhibit A
Exhibit B
Exhibit C
Exhibit D

Regional Reliability Standard BAL-002-WECC-3
White Paper – Contingency Reserve Request to Retire BAL-002-WECC-3
Summary of Development and Complete Record of Development
Standard Drafting Team Roster for WECC-0142

i

UNITED STATES OF AMERICA
BEFORE THE
FEDERAL ENERGY REGULATORY COMMISSION
North American Electric Reliability Corporation

)
)

Docket No. _______

JOINT PETITION OF THE
NORTH AMERICAN ELECTRIC RELIABILITY CORPORATION AND
WESTERN ELECTRICITY COORDINATING COUNCIL FOR APPROVAL OF
RETIREMENT OF REGIONAL RELIABILITY STANDARD BAL-002-WECC-3
Pursuant to Section 215(d)(1) of the Federal Power Act (“FPA”)1 and Section 39.5 of the
regulations of the Federal Energy Regulatory Commission (“FERC” or “Commission”),2 the North
American Electric Reliability Corporation (“NERC”)3 and the Western Electricity Coordinating
Council (“WECC”) hereby submit for Commission approval the retirement of Regional Reliability
Standard BAL-002-WECC-3 – Contingency Reserve.
Regional Reliability Standard BAL-002-WECC-3 requires applicable WECC entities to
maintain reserves at levels that exceed those required under the continent-wide Reliability
Standard BAL-002-3 – Disturbance Control Standard – Contingency Reserve for Recovery from
a Balancing Contingency Event. Following a recent review of the regional standard, WECC
identified that no technical basis supports the continued applicability of the standard, and that
rather than advance reliability in the Western Interconnection, the regional standard may be
presenting unnecessary challenges. WECC concluded that the retirement of Regional Reliability
Standard BAL-002-WECC-3 would enhance reliability in the Western Interconnection by
allowing resources that are currently required to be held as excess reserves to be used more

1

16 U.S.C. § 824o.
18 C.F.R. § 39.5 (2026).
3
The Commission certified NERC as the electric reliability organization (“ERO”) in accordance with
Section 215 of the FPA. N. Am. Elec. Reliability Corp., 116 FERC ¶ 61,062 (2006) [hereinafter ERO Certification
Order].
2

1

efficiently to support reliable system operations, particularly as the resource mix continues to
change with increasing levels of variable generation from Inverter-Based Resources (“IBR”), as
well as serve other important public interests.
For these reasons, which are explained more fully in this filing and the WECC Contingency
Reserve Request to Retire White Paper included as Exhibit B,4 NERC and WECC request that the
Commission approve the retirement of currently effective Regional Reliability Standard BAL-002WECC-3 as just, reasonable, not unduly discriminatory, and in the public interest. Retirement of
this unnecessary regional standard would be consistent with the Administration’s Executive Order
directing agencies to reduce unnecessary regulations.5
As required by Section 39.5(a) of the Commission’s regulations,6 this petition presents the
technical basis and purpose for retirement of the Regional Reliability Standard, and a summary of
the development history (Exhibit C), The NERC Board of Trustees adopted the proposal to retire
the Regional Reliability Standard on December 5, 2025.
I.

SUMMARY
The purpose of currently effective Regional Reliability Standard BAL-002-WECC-3 is to

specify the quantity and types of Contingency Reserve7 required to ensure reliable operation of the

4
5
6
7

WECC, Contingency Reserve Request to Retire (Jan. 2025) [hereinafter White Paper].
Exec. Order No. 14192, 90 Fed. Reg. 9065 (Jan. 31, 2025).
18 C.F.R. § 39.5(a).
Contingency Reserve is defined in the NERC Glossary as:
The provision of capacity that may be deployed by the Balancing Authority to
respond to a Balancing Contingency Event and other contingency requirements
(such as Energy Emergency Alerts as specified in the associated EOP standard).
A Balancing Authority may include in its restoration of Contingency Reserve
readiness to reduce Firm Demand and include it if, and only if, the Balancing
Authority:
• is experiencing a Reliability Coordinator declared Energy Emergency Alert
level, and is utilizing its Contingency Reserve to mitigate an operating emergency
in accordance with its emergency Operating Plan.
• is utilizing its Contingency Reserve to mitigate an operating emergency in
accordance with its emergency Operating Plan.

2

Western Interconnection under normal and abnormal conditions. The standard consists of four
requirements. Requirement R1 provides each Balancing Authority and each Reserve Sharing
Group to maintain a minimum amount of Contingency Reserve composed of any combination of
a list of specified reserve types. Requirement R2 was retired with the approval of BAL-002WECC-3 in Order No. 876.8 Requirements R3 and R4 require entities to maintain a minimum
amount of Operating Reserve and to restore Contingency Reserves within a set period after an
initiating event. Regional Reliability Standard BAL-002-WECC-3 has more stringent
requirements than the continent-wide equivalent, Reliability Standard BAL-002-3. Following a
recent review of the regional standard, WECC concluded that these more stringent requirements
are not benefiting the reliability of the Western Interconnection and instead could be inhibiting
reliability across the interconnection, and therefore the regional standard should be retired.
The Contingency Reserve levels and restoration times required by BAL-002-WECC-3 and
its predecessors are based on pre-standards practices from the 1990s and were the product of
contractual negotiations between the parties, rather than by a technical justification identifying a
specific reliability need for the mandated reserve levels. 9 Those reserve level and restoration
requirements, which were largely carried forward unchanged since 1996, exceed the requirements
that are applicable to the rest of the continent under the later-developed Reliability Standard BAL002-3. As a result, entities in the Western Interconnection are required to carry excess reserves and
faster restoration times than has been deemed necessary for reliability in the rest of North America.
WECC determined that a requirement to hold excess reserves not only hinders the effective
deployment of existing generation resources but could exacerbate reliability concerns raised by

8

Order No. 876, WECC Regional Reliability Standard BAL-002-WECC (Contingency Reserve), 175 FERC ¶
61,037 (2021).
9
White Paper at 8.

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the Commission regarding the reliable integration of variable generation in Order No. 901, 10
wherein FERC addresses the need for continent-wide standards to backstop the operational
performance of variable generation (largely IBRs).11
Retirement of Regional Reliability Standard BAL-002-WECC-3 would promote
consistency across the interconnections and allow resources, particularly those immediately
dispatchable such as hydroelectric generation, to be used more efficiently to support the reliability
of the Bulk-Power System as variable IBRs continue to grow among the resource mix. The
continent-wide Reliability Standard BAL-002-3 would continue to ensure that entities are required
to maintain Contingency Reserve levels determined to be sufficient to support the reliable
operation of the Bulk-Power System.
For these reasons, and as discussed more fully herein, NERC and WECC respectfully
request the Commission approve the retirement Regional Reliability Standard BAL-002-WECC3 as just, reasonable, not unduly discriminatory, and in the public interest. The following petition
presents the justification for retirement and supporting documentation.

10

Order No. 901, Reliability Standards to Address Inverter-Based Resources, 185 FERC ¶ 61,042 at P 11-15
(2023) [hereinafter Order No. 901].
11
Id. At P 24 (“[W]e continue to find that as the resource mix trends towards higher penetrations of IBRs, the
need to reliably integrate these resources into the Bulk-Power System is expected to grow, and that the currently
effective Reliability Standards do not adequately address IBR reliability risks. The continuing risks that the
increasing penetration of IBRs pose to the reliable operation of the Bulk-Power System underscore the need for
mandatory Reliability Standards to address these issues on a nationwide basis.”).

4

II.

NOTICES AND COMMUNICATIONS
Notices and communications with respect to this filing may be addressed to the following:12

Chris Albrecht*
Assistant General Counsel
Steve Rueckert*
Director of Standards
Western Electricity Coordinating Council
155 North 400 West, Suite 200
Salt Lake City, UT 84103
(801) 582-0353
[email protected]
[email protected]
III.

Lauren Perotti*
Assistant General Counsel
Alain Rigaud*
Associate Counsel
North American Electric Reliability
Corporation
1401 H Street, N.W., Suite 410
Washington, D.C. 20005
(202) 400-3000
[email protected]
[email protected]

BACKGROUND
The following background information is provided below: (1) an explanation of the

regulatory framework; (2) a description of the WECC Reliability Standards Development
Procedure; and (3) procedural history of BAL-002-WECC-3, and (4) the history of Project
WECC-0142: Request to Retire BAL-002-WECC-3, Contingency Reserve.
a. Regulatory Framework
By enacting the Energy Policy Act of 2005,13 Congress entrusted the Commission with the
duties of approving and enforcing rules to ensure the reliability of the Bulk-Power System, and
with the duty of certifying an ERO that would be charged with developing and enforcing
mandatory Reliability Standards, subject to Commission approval. Section 215(b)(1) of the FPA
states that all users, owners, and operators of the Bulk-Power System in the United States will be
subject to Commission-approved Reliability Standards.14 Section 215(d)(5) of the FPA authorizes

12

NERC and WECC respectfully request a waiver of Rule 203 of the Commission’s regulations, 18 C.F.R. §
385.203, to allow the inclusion of more than two persons on the service list in this proceeding.
13
16 U.S.C. § 824o.
14
Id. § 824(b)(1).

5

the Commission to order the ERO to submit a new or modified Reliability Standard.15 Section
39.5(a) of the Commission’s regulations requires the ERO to file for Commission approval each
Reliability Standard that the ERO proposes should become mandatory and enforceable in the
United States, and each modification to a Reliability Standard that the ERO proposes to make
effective.16
The Commission has the regulatory responsibility to approve Reliability Standards that
protect the reliability of the Bulk-Power System and to ensure that such Reliability Standards are
just, reasonable, not unduly discriminatory or preferential, and in the public interest. Pursuant to
Section 215(d)(2) of the FPA and Section 39.5(c) of the Commission’s regulations, the
Commission will give due weight to the technical expertise of the ERO with respect to the content
of a Reliability Standard.17
Similarly, the Commission approves regional differences proposed by Regional Entities,
such as Regional Reliability Standards and Variances, if the regional difference is just, reasonable,
not unduly discriminatory or preferential, and in the public interest.18 In addition, Commission
Order No. 672 requires further criteria for regional differences. A regional difference from a
continent-wide Reliability Standard must either be: (1) more stringent than the continent-wide
Reliability Standard, including a regional difference that addresses matters that the continent-wide
Reliability Standard does not; or (2) necessitated by a physical difference in the Bulk-Power
System.19 The Commission must give due weight to the technical expertise of a Regional Entity,

15
16
17
18
19

Id. § 824o(d)(5).
18 C.F.R. § 39.5(a).
16 U.S.C. § 824o(d)(2); 18 C.F.R. § 39.5(c)(1).
16 U.S.C. § 824o(d)(2) and 18 C.F.R. § 39.5(a).
Order No. 672 at P 291.

6

like WECC, that is organized on an Interconnection-wide basis, with respect to a regional
difference to be applicable within that Interconnection.20
b. WECC Reliability Standards Development Procedure
The proposed retirement of the Regional Reliability Standard was developed in an open
and fair manner and in accordance with the Commission-approved WECC Reliability Standards
Development Procedures (“RSDP”). 21 WECC’s RSDP provides for reasonable notice and
opportunity for public comment, due process, openness, and a balance of interests in developing
Reliability Standards and thus addresses several of the Commission’s criteria for approving
Reliability Standards. The development process is open to any person or entity that is an interested
stakeholder. WECC considers the comments of all stakeholders, and a vote of stakeholders and
the WECC Board of Directors is required to approve or retire a WECC regional Reliability
Standard. NERC posts each regional Variance developed by a Regional Entity for an additional
comment period. The NERC Board of Trustees must adopt the proposal for regional Variance
before it is submitted to the Commission for approval.
c. Procedural History of BAL-002-WECC-3
As further described in Exhibit B hereto, the Contingency Reserve thresholds in Regional
Reliability Standard BAL-002-WECC-3 were originally developed in 1996, when the Western
Systems Coordinating Council (“WSCC”) adopted the WSCC Reliability Criteria, Minimum
Operating Reliability Criteria (“MORC”). In 1999, the MORC became the WECC Reliability
Management System (“RMS”), a contract-based system of accountability that pre-dated

20

Id. at P 344.
The currently effective WECC RSDP was approved by the Commission on September 13, 2021. See N.
Am. Elec. Reliability Corp., RR21-4-000 (Sep. 13, 2021) (approving revised WECC Reliability Standards
Development Procedures). The WECC Reliability Standards Development Procedures are available at:
https://www.wecc.org/sites/default/files/documents/standards/2024/WECC%20Reliability%20Standards%20Develo
pment%20Procedures%20-%20FERC%20Approved%2009-13-2021.pdf.

21

7

mandatory standards. As the industry transitioned to mandatory standards and memorialization of
legacy operating practices, the criteria and language of the RMS were adapted into several
Regional Reliability Standards without substantive revision and one of them was approved as
WECC-BAL-STD-002-0, Operating Reserves, in 2007. 22 The reserves levels originally
established in the MORC remained the same and were carried forward.
In 2013, the Commission approved Regional Reliability Standard BAL-002-WECC-2 –
Contingency Reserve in Order No. 789.23 In approving the regional standard, the Commission
found that it contained a more stringent set of requirements than those provided in the continentwide disturbance control standard in effect at that time, Reliability Standard BAL-002-1 –
Disturbance Control Performance. 24 In 2017, an interpretation (BAL-002-WECC-2a) was
developed and later incorporated into BAL-002-WECC-3, in which Requirement R2 was retired,
which was approved by the Commission on April 15, 2021.25
d. Development of the Proposed Retirement of the Regional Reliability
Standard
As further described in Exhibit B hereto, WECC determined that Regional Reliability
Standard BAL-002-WECC-3 should be retired in accordance with the WECC RSDP. On August
14, 2020, WECC received a Standard Authorization Request seeking to retire Regional Reliability
Standard BAL-002-WECC-2a, the effective version of the standard at that time. The request
asserted that freeing up reserves from the Contingency Reserve requirement would increase the
availability of resources to manage variable generation and accommodate increased IBR

22

N. Am. Elec. Reliability Corp., 119 FERC ¶ 61,260 (2007).
Order No. 789, Regional Reliability Standard BAL-002-WECC-2 – Contingency Reserve, 145 FERC ¶
61,141 at P 1 (2013).
24
Id. at P 26.
25
Supra note 9, Order No. 876 at P 2 (“…implementation of the continent-wide Reliability Standard BAL003-1.1 (Frequency Response and Frequency Bias Setting), Requirement R1 makes Requirement R2 redundant.”).
23

8

integration in Western Interconnection without diminishing the ability to meet the deployment
requirements under the continent-wide Reliability Standard BAL-002-3.
In March 2022, the project was placed in abeyance, and the drafting team was tasked with
developing a white paper evaluating the technical basis for retirement of the standard.26 In 2024,
the drafting team reconvened and finished developing the white paper.27 WECC posted the white
paper for public comment from November 15, 2024 through January 15, 2025. The white paper
set forth the drafting team’s rationale for retiring the Regional Reliability Standard.
On May 15, 2025 WECC ballot body approved the proposal to retire Regional Reliability
Standard BAL-002-WECC-3. The WECC Board of Directors approved the retirement of the
Regional Reliability Standard on June 11, 2025. NERC posted the Regional Reliability Standard
for a 45-day comment period from September 16, 2025 through October 30, 2025. Most of the
comments were favorable to the proposed retirement of the Regional Reliability Standard. A
minority commenter raised concerns about significant events that occurred in the Western
Interconnection impacting IBR performance that may have benefitted from having additional
reserves, and asserted that the more stringent criteria in BAL-002-WECC-3 may have alleviated
some of those events.28 The WECC drafting team considered this comment, determining that that
there is no technical evidence that the extra reserves improve reliability, but rather it could harm
reliability as maintaining excess Contingency Reserves reduces system and operational
flexibility.29 The NERC Board of Trustees adopted the proposal to retire Regional Reliability
Standard BAL-002-WECC-3 on December 5, 2025.

26

Exhibit C, Summary of Development and Complete Record of Development, Notice of Abeyance.
Exhibit B, White Paper.
28
Exhibit C, NERC Development History, Comments Received (AZPS comments).
29
See e.g., Exhibit C, Summary of Development and Complete Record of Development, WECC Response to
AZPS comment; White Paper at 13.
27

9

IV.

JUSTIFICATION FOR RETIREMENT
As discussed in detail in the white paper in Exhibit B, the proposed retirement of Regional

Reliability Standard BAL-002-WECC-3 is just, reasonable, not unduly discriminatory or
preferential, and in the public interest. Regional Reliability Standard BAL-002-WECC-3 and its
predecessors impose more stringent Contingency Reserve requirements for entities in the Western
Interconnection than those required under the continent-wide disturbance control standard,
Reliability Standard BAL-002-3. In the white paper, WECC concluded that these more stringent
requirements have not been shown to provide additional reliability benefits to the Western
Interconnection but rather could be inhibiting reliability across the interconnection by reducing
operational flexibility and leading to the inefficient use of excess resources.
The retirement of Regional Reliability Standard BAL-002-WECC-3 would increase the
availability of reserves currently held as excess Contingency Reserves to better support system
operations and manage variable generation concerns. 30 Retirement would also increase the
restoration timeframe for Contingency Reserves after a contingency event occurs and increase an
entity’s ability to secure additional resources. Bulk-Power System reliability would continue to be
maintained through the continent-wide Reliability Standard BAL-002-3 by requiring sufficient
Contingency Reserves are maintained and a restoration timeframe that is compatible with market
scheduling practices.
Below is requirement-by-requirement summary explaining why the proposed standard
should be retired. For additional support and information, please refer to the white paper, included
as Exhibit B, to this filing.

30

Supra note 11, Order No. 901 at P 11-15.

10

a. Retirement of Requirement R1
Requirement R1 of Regional Reliability Standard BAL-002-WECC-3 imposes more
stringent Contingency Reserve requirements than the Contingency Reserve requirements in the
continent-wide disturbance control standard, Reliability Standard BAL-002-3. Requirement R1
of Reliability Standard BAL-002-3 requires the Balancing Authority and Reserve Sharing Group
to have a Contingency Reserve only up to its most severe single contingency (“MSSC”) and does
not require Contingency Reserve deployment beyond the MSSC. By contrast, Requirement R1
Part 1.1 of the Regional Reliability Standard requires the Balancing Authority and Reserve Sharing
Group to maintain at a minimum the greater amount of Contingency Reserve equal to the loss of
the MSSC or the amount of Contingency Reserve equal to the sum of 3% of hourly integrated load
and 3% of hourly integrated generation. Because the Contingency Reserve must be the greater of
either of these totals, entities could be required to hold reserves beyond that of MSSC. As a result,
entities in the Western Interconnection can be required to hold Contingency Reserves that exceed
what is required in the other interconnections.
While this regional requirement is more stringent than the continent-wide requirement,
WECC has concluded that it is not in fact necessary to ensure or advance reliability in the Western
Interconnection. As noted above, the Contingency Reserve thresholds in Regional Reliability
Standard BAL-002-WECC-3 are legacy requirements that were carried over from the MORC and
long pre-date the development of the continent-wide Reliability Standard BAL-002-3. In its recent
analysis of the regional standard, WECC has identified no technical justification or other
foundation showing that holding more Contingency Reserves than what is required under
Reliability Standard BAL-002-3 enhances the reliability of the Western Interconnection.31 WECC,

31

See Exhibit B, White Paper at 2.

11

however, has identified that requiring Contingency Reserves beyond the MSSC reduces the
capacity available to meet other reliability needs in the Western Interconnection, such as load and
resource balancing in real time.32 A comparison of the hourly Contingency Reserve Requirement
(calculated using 3% generation and 3% load) to MSSC, showed that there was more than 5,000
MW of capacity available during the summertime peak hours and between 2,000-2,500 MW
during the remaining hours of the year.33 In application, these excess reserves consist of significant
amounts of generation that is dispatchable, frequency responsive, and fast ramping.34 Generation
that could be used to meet ramps, support the reliable integration of variable IBRs, or simply meet
expected loads is instead committed to continency reserve capacity that is not available to serve
load.35 Instead, these reserves are unused or unloaded generation that are in a state of readiness in
case there is sudden loss of loaded generation. As a result, requiring entities to maintain more
reserves than the MSSC restricts their ability to meet the immediate balancing needs of the
Interconnection, and ultimately detracts from reliability.
Retirement of this requirement in BAL-002-WECC-3 would allow more resources to be
deployed more effectively to address real-time balancing needs and would promote a consistent
continent-wide approach to Contingency Reserves as set forth in the continent-wide Reliability
Standard BAL-002-3.36
b. Requirement R2
Requirement R2 of Regional Reliability Standard BAL-002-WECC-3 was retired when
this version of the standard was approved in 2021. 37 Requirement R2 was determined to be

32
33
34
35
36
37

See Id. at 22.
See Id. at 16, Figure 1.
See Id. at 17.
Id.
Id. at 22-23.
Supra note 9, Order No. 876.

12

redundant as Requirement R1 of the then effective continent-wide Reliability Standard BAL003.1.1.38 The retirement was supported by the results of a field test WECC conducted to measure
the effects of retiring Requirement R2, from which WECC determined that no degradation of
performance occurred during the test period, and entities deployed enough reserves for post
disturbance Area Control Area recovery. 39 A post-implementation informational filing further
confirmed that the retirement of Requirement R2 did not have any unexpected, adverse impacts
on contingency reserves in the Western Interconnection.40
c. Retirement of Requirements R3 and R4
Requirements R3 and R4 of Regional Reliability Standard BAL-002-WECC-3 require the
Balancing Authority and Reserve Sharing Group to restore Contingency Reserve within 60
minutes of the event initiating. In contrast, Reliability Standard BAL-002-3 requires the restoration
of Contingency Reserve within 90 minutes following the end of the Contingency Event Recovery
Period.41 As a result, Regional Reliability Standard BAL-002-WECC-3 requires the performance
of the same task 45 minutes earlier than its continent-wide counterpart. This shortened restoration
timeframe restricts an entity’s ability to secure additional resources and may force entities into
transactions in an arbitrarily shortened timeframe.
The 60-minute restoration requirement, like the Contingency Reserve thresholds in
Requirement R1, is a legacy provision that was carried over from the MORC. In 1996, when the
MORC was developed, resource deployment was more flexible as transactions were bilateral and

38

Id. at P 2.
Id. at PP 12-13.
40
Compliance Filing of the N. Am. Elec. Reliability Corp. and Western Electricity Coordinating Council in
Response to Order No. 876, Docket No. RM19-20-000 (Dec. 15, 2023).
41
Contingency Event Recovery Period is defined as: “A period that begins at the time that the resource output
begins to decline within the first one- minute interval of a Reportable Balancing Contingency Event, and extends for
fifteen minutes thereafter.”
39

13

could be executed more quickly.42 However, under today’s market practices, transactions take
more time to execute as they require advanced schedules and must be submitted and approved well
in advance; this limits the ability to replace lost resources on short notice.43 WECC has identified
no technical justification that supports a shortened restoration window as enhancing reliability in
the Western Interconnection.44 Instead, the 60-minute restoration requirement hurts liquidity and
arbitrarily limits an entity’s time and ability to replace lost resources through market practices,
which could result in an entity needing to enter an Energy Emergency Alert 3 45 to deploy
Contingency Reserves in order to serve load.46
In contrast, the Contingency Reserve Restoration Period 47 within the continent-wide
Reliability Standard BAL-002-3 allows applicable entities to use normal market scheduling
practices to replace lost generation. 48 For reasons stated more fully in the Commission’s
proceeding approving that standard, the timeframe described in the Contingency Reserve
Restoration Period is adequate for the reliable operation of the Bulk-Power System.49 Retirement

42

Exhibit B, White Paper at 17.
Id.
44
Id. at 16-17.
45
Energy Emergency Alert 3 is defined in EOP-011-4 Attachment 1(B)(3) as: (“Firm Load interruption is
imminent or in progress. Circumstances: • The energy deficient Balancing Authority is unable to meet minimum
Contingency Reserve requirements.”).
46
See e.g., Id. at 17.
From January 2020 through May 2024, WECC recorded 19 Energy Emergency Alert 3s for entities based
in the United States, 7 of which involved entities tied to a Reserve Sharing Group. Based on data collected from
these events, WECC estimates that up to 9 of the 19 Energy Emergency Alert 3s may not have been necessary if the
BAL-002-WECC standard had been retired and only the continent-wide standard was enforceable.
47
Contingency Reserve Restoration Period is defined as: (“A period not exceeding 90 minutes following the
end of the Contingency Event Recovery Period.”).
48
Exhibit B, White Paper at 17.
49
Order No. 835, Disturbance Control Standard-Contingency Reserve for Recovery from a Balancing
Contingency Event Reliability Standard, 158 FERC ¶ 61,030 (2017) (Order approving BAL-002-2 and the term
Contingency Reserve Restoration Period); Information Filing of the N. Am. Elec. Reliability Corp. Regarding
Implementation of Reliability Standard BAL-002-2, Docket Nos. RM16-7; RD18-7 (Jan. 20, 2020) at 4 (“NERC
found that there were no events reported with additional megawatt losses following Reportable Balancing
Contingency Events during the Contingency Reserve Restoration Period.”).
43

14

of Requirements R3 and R4 in BAL-002-WECC-3 would allow entities in the Western
Interconnection more time to restore Contingency Reserve and to use normal established market
scheduling practices.50
The retirement of Regional Reliability Standard BAL-002-WECC-3 would ensure there is
a consistent approach regarding Contingency Reserve restoration requirements across all the
interconnections. It would also give entities within the Western Interconnection more time to react
to a contingency event and determine how to properly restore their lost resources. Reliability in
the Western Interconnection would be maintained under Reliability Standard BAL-002-3 and
could be enhanced by allowing more operational flexibility and efficient use of excess resources.
V.

EFFECTIVE DATE
NERC and WECC respectfully request that the Commission approve the proposed

retirement of the Regional Reliability Standard to become effective on the first day of the first
quarter following the effective date of the Commission’s order approving the proposed retirement.

50

Id.

15

VI.

CONCLUSION
For the reasons set forth above, NERC and WECC respectfully request that the

Commission approve the retirement of Regional Reliability Standard BAL-002-WECC-3,
effective as proposed herein.

Respectfully submitted,
/s/ Alain Rigaud

Chris Albrecht*
Assistant General Counsel
Western Electricity Coordinating Council
155 North 400 West, Suite 200
Salt Lake City, UT 84103
(801) 582-0353
[email protected]
Counsel for the Western Electricity
Coordinating Council

Lauren Perotti*
Assistant General Counsel
Alain Rigaud*
Associate Counsel
North American Electric Reliability Corporation
1401 H Street, N.W., Suite 410
Washington, D.C. 20005
(202) 400-3000
[email protected]
[email protected]
Counsel for the North American Electric Reliability
Corporation

Date: February 27, 2026

16

Exhibit A
Regional Reliability Standard
BAL-002-WECC-3

BAL-002-WECC-3—Contingency Reserve

A. Introduction
1.

Title:

Contingency Reserve

2.

Number:

BAL-002-WECC-3

3.

Purpose:

To specify the quantity and types of Contingency Reserve required to
ensure reliability under normal and abnormal conditions.

4.

Applicability:
4.1. Functional Entities:
4.1.1 Balancing Authority
4.1.1.1

The Balancing Authority is the responsible entity unless the
Balancing Authority is a member of a Reserve Sharing Group, in
which case, the Reserve Sharing Group becomes the responsible
entity.

4.1.2 Reserve Sharing Group

5.

4.1.2.1

The Reserve Sharing Group when comprised of a Source Balancing
Authority becomes the source Reserve Sharing Group.

4.1.2.2

The Reserve Sharing Group when comprised of a Sink Balancing
Authority becomes the sink Reserve Sharing Group.

Effective Date:

Immediately upon receipt of regulatory approval.

B. Requirements and Measures
R1.

Each Balancing Authority and each Reserve Sharing Group shall maintain a minimum
amount of Contingency Reserve, except within the first sixty minutes following an
event requiring the activation of Contingency Reserve, that is: [Violation Risk Factor:
High] [Time Horizon: Real-time operations]
1.1. The greater of either:
•

The amount of Contingency Reserve equal to the loss of the most severe
single contingency;

•

The amount of Contingency Reserve equal to the sum of three percent of
hourly integrated Load plus three percent of hourly integrated generation.

1.2. Composed of any combination of the reserve types specified below:
•

Operating Reserve—Spinning

•

Operating Reserve—Supplemental

•

Interchange Transactions designated by the Source Balancing Authority as
Operating Reserve—Supplemental

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BAL-002-WECC-3—Contingency Reserve

•

Reserve held by other entities by agreement that is deliverable on Firm
Transmission Service

•

A resource, other than generation or load, that can provide energy or reduce
energy consumption

•

Load, including demand response resources, Demand-Side Management
resources, Direct Control Load Management, Interruptible Load or
Interruptible Demand, or any other Load made available for curtailment by
the Balancing Authority or the Reserve Sharing Group via contract or
agreement.

•

All other load, not identified above, once the Reliability Coordinator has
declared an energy emergency alert signifying that firm load interruption is
imminent or in progress.

1.3. Based on real-time hourly load and generating energy values averaged over each
Clock Hour (excluding Qualifying Facilities covered in 18 C.F.R.§ 292.101, as
addressed in FERC Order 464).
1.4. An amount of capacity from a resource that is deployable within ten minutes.
M1. Each Balancing Authority and each Reserve Sharing Group will have documentation
demonstrating its Contingency Reserve was maintained, except within the first sixty
minutes following an event requiring the activation of Contingency Reserve.
Part 1.1
Each Balancing Authority and each Reserve Sharing Group will have dated
documentation that demonstrates its Contingency Reserve was maintained in
accordance with the amounts identified in Requirement R1, Part 1.1, except within the
first sixty minutes following an event requiring the activation of Contingency Reserve.
Attachment A is a practical illustration showing how the generation amount may be
calculated under Requirement R1.
•

•

Where Dynamic Schedules are used as part of the generation amount upon
which Contingency Reserve is predicated, additional evidence of compliance
with Requirement R1, Part 1.1 may include, but is not limited to,
documentation showing a reciprocal acknowledgement as to which entity is
carrying the reserves. This transfer may be all or some portion of the physical
generator and is not limited to the entire physical capability of the generator.
Where Pseudo-Ties are used as part of the generation amount upon which
Contingency Reserve is predicated, additional evidence of compliance with
Requirement R1, Part 1.1, may include, but is not limited to, documentation
accounting for the transfers included in the Pseudo-Ties.

Part 1.2
Each Balancing Authority and each Reserve Sharing Group will have dated
documentation that demonstrates compliance with Requirement R1, Part 1.2.
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BAL-002-WECC-3—Contingency Reserve

Evidence may include, but is not limited to, documentation that reserves were
comprised of the types listed in Requirement R1, Part 1.2 for purposes of meeting the
Contingency Reserve obligation of Requirement R1. Additionally, for purposes of the
last bullet of Requirement R1, Part 1.2, evidence of compliance may include, but is not
limited to, documentation that the reliability coordinator had issued an energy
emergency alert, indicating that firm Load interruption was imminent or was in
progress.
Part 1.3
Each Balancing Authority and each Reserve Sharing Group will have dated
documentation that demonstrates compliance with Requirement R1, Part 1.3.
Evidence of compliance with Requirement R1, Part 1.3 may include, but is not limited
to, documentation that Contingency Reserve amounts are based upon load and
generating data averaged over each Clock Hour and excludes Qualifying Facilities
covered in 18 C.F.R.§ 292.101, as addressed in FERC Order 464.
Part 1.4
Evidence of compliance with Requirement R1, Part 1.4 may include, but is not limited
to, documentation that the reserves maintained to comply with Requirement R1, Part
1.4 are fully deployable within ten minutes.
R2. Reserved.
M2. Reserved.
R3.

Each Sink Balancing Authority and each sink Reserve Sharing Group shall maintain an
amount of Operating Reserve, in addition to the minimum Contingency Reserve in
Requirement R1, equal to the amount of Operating Reserve–Supplemental for any
Interchange Transaction designated as part of the Source Balancing Authority’s
Operating Reserve–Supplemental or source Reserve Sharing Group’s Operating
Reserve–Supplemental, except within the first sixty minutes following an event
requiring the activation of Contingency Reserve. [Violation Risk Factor: High] [Time
Horizon: Real-time operations]

M3. Each Sink Balancing Authority and each sink Reserve Sharing Group will have dated
documentation demonstrating it maintained an amount of Operating Reserve, in
addition to the Contingency Reserve identified in Requirement R1, equal to the
amount of Operating Reserve–Supplemental for any Interchange Transaction
designated as part of the Source Balancing Authority’s Operating Reserve–
Supplemental or source Reserve Sharing Group’s Operating Reserve–Supplemental,
for the entire period of the transaction, except within the first sixty minutes following
an event requiring the activation of Contingency Reserves, in accordance with
Requirement 3.
R4.

Each Source Balancing Authority and each source Reserve Sharing Group shall
maintain an amount of Operating Reserve, in addition to the minimum Contingency
Reserve amounts identified in Requirement R1, equal to the amount and type of

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BAL-002-WECC-3—Contingency Reserve

Operating Reserves for any Operating Reserve transactions for which it is the Source
Balancing Authority or source Reserve Sharing Group. [Violation Risk Factor: High]
[Time Horizon: Real-time operations]
M4. Each Source Balancing Authority and each source Reserve Sharing Group will have
dated documentation that demonstrates it maintained an amount of additional
Operating Reserves identified in Requirement R1, greater than or equal to the amount
and type of that identified in Requirement 4, for the entire period of the transaction.

C. Compliance
1.

Compliance Monitoring Process
1.1. Compliance Enforcement Authority:
For entities that do not work for the Regional Entity, the Regional Entity shall
serve as the Compliance Enforcement Authority.
For Reliability Coordinators and other functional entities that work for their
Regional Entity, the ERO or a Regional Entity approved by the ERO and FERC or
other applicable governmental authorities shall serve as the Compliance
Enforcement Authority.
For responsible entities that are also Regional Entities, the ERO or a Regional
Entity approved by the ERO and FERC or other applicable governmental
authorities shall serve as the Compliance Enforcement Authority.
1.2. Compliance Monitoring and Assessment Processes:
Compliance Audit
Self-Certification
Spot-Checking
Compliance Investigation
Self-Reporting
Complaint
1.3.

Evidence Retention:
The following evidence retention periods identify the period of time an entity is
required to retain specific evidence to demonstrate compliance. For instances
where the evidence retention period specified below is shorter than the time
since the last audit, the Compliance Enforcement Authority may ask an entity to
provide other evidence to show that it was compliant for the full-time period
since the last audit.
Each Balancing Authority and each Reserve Sharing Group shall keep evidence
for Requirement R1 through R4 for three years plus calendar current.

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BAL-002-WECC-3—Contingency Reserve

1.4. Additional Compliance Information:
1.4.1 This Standard shall apply to each Balancing Authority and each Reserve
Sharing Group that has registered with WECC as provided in Part 1.4.2 of
Section C.
Each Balancing Authority identified in the registration with WECC as
provided in Part 1.4.2 of Section C shall be responsible for compliance with
this Standard through its participation in the Reserve Sharing Group and
not on an individual basis.
1.4.2 A Reserve Sharing Group may register as the Responsible Entity for
purposes of compliance with this Standard by providing written notice to
the WECC: 1) indicating that the Reserve Sharing Group is registering as the
Responsible Entity for purposes of compliance with this Standard, 2)
identifying each Balancing Authority that is a member of the Reserve
Sharing Group, and 3) identifying the person or organization that will serve
as agent on behalf of the Reserve Sharing Group for purposes of
communications and data submissions related to or required by this
Standard.
1.4.3 If an agent properly designated in accordance with Part 1.4.2 of Section C
identifies individual Balancing Authorities within the Reserve Sharing Group
responsible for noncompliance at the time of data submission, together
with the percentage of responsibility attributable to each identified
Balancing Authority, then, except as may otherwise be finally determined
through a duly conducted review or appeal of the initial finding of
noncompliance: 1) any penalties assessed for noncompliance by the
Reserve Sharing Group shall be allocated to the individual Balancing
Authorities identified in the applicable data submission in proportion to
their respective percentages of responsibility as specified in the data
submission, 2) each Balancing Authority shall be solely responsible for all
penalties allocated to it according to its percentage of responsibility as
provided in subsection 1) of this Part 1.4.3 of Section C, and 3) neither the
Reserve Sharing Group nor any member of the Reserve Sharing Group shall
be responsible for any portion of a penalty assessed against another
member of the Reserve Sharing Group in accordance with subsection 1) of
this Part 1.4.3 of Section C (even if the member of Reserve Sharing Group
against which the penalty is assessed is not subject to or otherwise fails to
pay its allocated share of the penalty).
1.4.4 If an agent properly designated in accordance with Part 1.4.2 of Section C
fails to identify individual Balancing Authorities within the Reserve Sharing
Group responsible for noncompliance at the time of data submission or
fails to specify percentages of responsibility attributable to each identified
Balancing Authority, any penalties for noncompliance shall be assessed
against the agent on behalf of the Reserve Sharing Group, and it shall be
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BAL-002-WECC-3—Contingency Reserve

the responsibility of the members of the Reserve Sharing Group to allocate
responsibility for such noncompliance.
1.4.5 Any Balancing Authority that is a member of a Reserve Sharing Group that
has failed to register as provided in Part 1.4.2 of Section C shall be subject
to this Standard on an individual basis.

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BAL-002-WECC-3—Contingency Reserve

Violation Severity Levels
Violation Severity Levels
R#

Lower VSL

Moderate VSL

High VSL

Severe VSL

R1.

The Balancing Authority or
the Reserve Sharing Group
that incurs one Clock Hour,
during a calendar month, in
which Contingency Reserve
is less than 100% but greater
than or equal to 90% of the
required Contingency
Reserve amount, with the
characteristics specified in
Requirement R1.

The Balancing Authority or
the Reserve Sharing Group
that incurs one Clock Hour,
during a calendar month, in
which Contingency Reserve
is less than 90% but greater
than or equal to 80% of the
required Contingency
Reserve amount, with the
characteristics specified in
Requirement R1.

The Balancing Authority or
the Reserve Sharing Group
that incurs one Clock Hour,
during a calendar month, in
which Contingency Reserve
is less than 80% but greater
than or equal to 70% of the
required Contingency
Reserve amount, with the
characteristics specified in
Requirement R1.

The Balancing Authority or
the Reserve Sharing Group
that incurs one Clock Hour,
during a calendar month, in
which Contingency Reserve
is less than 70% of the
required Contingency
Reserve amount, with the
characteristics specified in
Requirement R1.

R2.

Reserved.

R3.

The Balancing Authority or
the Reserve Sharing Group
that incurs one hour, during
a calendar month, in which
Contingency Reserve is less
than 100% but greater than
or equal to 90% of the
required Operating Reserve
amount specified in
Requirement R3.
The Balancing Authority or
the Reserve Sharing Group

The Balancing Authority or
the Reserve Sharing Group
that incurs one hour, during
a calendar month, in which
Contingency Reserve is less
than 90% but greater than or
equal to 80% of the required
Operating Reserve amount
specified in Requirement R3.

The Balancing Authority or
the Reserve Sharing Group
that incurs one hour, during
a calendar month, in which
Contingency Reserve is less
than 80% but greater than
or equal to 70% of the
required Operating Reserve
amount specified in
Requirement R3.
The Balancing Authority or
the Reserve Sharing Group

The Balancing Authority or
the Reserve Sharing Group
that incurs one hour, during
a calendar month, in which
Contingency Reserve is less
than 70% of the required
Operating Reserve amount
specified in Requirement R3.

R4.

The Balancing Authority or
the Reserve Sharing Group

The Balancing Authority or
the Reserve Sharing Group

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BAL-002-WECC-3—Contingency Reserve

that incurs one hour, during
a calendar month, in which
Contingency Reserve
Operating Reserve is less
than 100% but greater than
or equal to 90% of the
required Operating Reserve
amount specified in
Requirement R4.

that incurs one hour, during
a calendar month, in which
Contingency Reserve
Operating Reserve is less
than 90% but greater than or
equal to 80% of the required
Operating Reserve amount
specified in Requirement R4.

that incurs one hour, during
a calendar month, in which
Contingency Reserve
Operating Reserve is less
than 80% but greater than
or equal to 70% of the
required Operating Reserve
amount specified in
Requirement R4.

that incurs one hour, during
a calendar month, in which
Contingency Reserve
Operating Reserve is less
than 70% of the required
Operating Reserve amount
specified in Requirement R4.

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BAL-002-WECC-3—Contingency Reserve

D. Regional Variances
None.

E. Interpretations
None.

F. Associated Documents
None.

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BAL-002-WECC-3—Contingency Reserve

Version History
Version

Date

1

October 29, 2008

1

October 21, 2010

2

November 7, 2012

2

November 21, 2013

2a

December 1, 2015

Approved by WECC Board
of Directors

2a

January 24, 2017

FERC approved

3

August 15, 2019

Action

Change Tracking

Adopted by NERC Board
of Trustees
Order issued remanding
BAL-002-WECC-1
Adopted by NERC Board
of Trustees
FERC Order issued
approving BAL-002WECC-2. (Order becomes
effective 1/28/14.)

Adopted by the NERC
Board of Trustees

3

April 15, 2021

FERC approved

3

June 28, 2021

Effective Date of
Standard

Clarified resources
available for use in
Requirement R2
The Interpretation
provides clarification
regarding the types of
resources that may be
used to satisfy
Contingency Reserve.
The Interpretation was
removed. Requirement
R2 was deleted.
Template and
formatting were
updated. Syntax and
verb tense in Guideline
section were
corrected.
Docket(s): RM19-20-000
Description: Order No.
876: Final Rule re WECC
Regional Reliability
Standard BAL-002-WECC3 (Contingency Reserve)
under RM19-20.

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BAL-002-WECC-3—Contingency Reserve

Standard Attachments
Attachment A
Attachment A is illustrative only; it is not a requirement. Requirement R1 calls for an amount of
Contingency Reserve to be maintained, predicated on an amount of generation and load
required in Requirement R1, Part 1.1., specifically:
“1.1

The greater of either:
•

The amount of Contingency Reserve equal to the loss of the most severe
single contingency;

•

The amount of Contingency Reserve equal to the sum of three percent of
hourly integrated Load plus three percent of hourly integrated generation.”

Attachment A illustrates one possible way to account for and calculate the amount of
generation upon which the Contingency Reserve amount is predicated.
Below is a practical illustration showing how the generation amount may be calculated under
Requirement R1 for Balancing Authorities (BA) and Reserve Sharing Groups (RSG).
BA1 / RSG 1

Generation

Part of Generator

Generator 1
Generator 2
Generator 3 (Pseudo-Tied out to BA2)
Generator 4 QF (has backup contract)
Generator 5 QF in EMS
Generator 6

300 MWs online
200 MWs online
100 MWs online
10 MWs online
10 MWs online
0 MWs online

Yes
Yes
No
No
Yes
Yes

Dynamic Schedule to BA2 from BA11

(50 MWs)

Generation
BA generation (EMS)
Generation to use Under BAL-002-WECC-1

620 MWs
510 MWs
460 MWs**

(The sum of gen 1–6)
(The sum of gen 1, 2, and 5)
(The sum of gen 1, 2, and 5
minus Dynamic Schedule)

** Assumes BA1 and BA2 agree on Dynamic Schedule treatment. If no agreement, BA1 would
maintain reserves based on 510 MWs Generation.
BA2 / RSG2

Generation

Part of Generator

Generator 11
Generator 12
Generator 3 (Pseudo-Tied in from BA1)

100 MWs
100 MWs
100 MWs

Yes
Yes
Yes

Dynamic Schedule from BA1 to BA2

50 MWs

Yes

Generation
BA generation (EMS)

300 MWs
300 MWs

(The sum of gen 11, 12 and 3.)
(The sum of gen 11, 12 and 3)

1

Note: This Dynamic Schedule is not the same as the Generator 3 Pseudo-Tie.

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BAL-002-WECC-3—Contingency Reserve

Generation to use Under BAL-002-WECC-1

350 MWs**

(The sum of gen 11, 12 and 3
plus Dynamic Schedule)

** Assumes BA1 and BA2 agree on Dynamic Schedule treatment. If no agreement, BA1 would
have to maintain reserves based on 510MWs Generation and BA2 would determine its
generation to be 300 MWs.

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BAL-002-WECC-3—Contingency Reserve (Attachment C)—Supplemental Material

Guideline and Technical Basis
A Guidance Document addressing implementation of this standard was filed with Version 2.

Page 13 of 13

Exhibit B
White Paper
Contingency Reserve Request to Retire BAL-002-WECC-3

WECC-0142 BAL-002-WECC-3
Contingency Reserve
Request to Retire
WECC-0142 Drafting Team
01/21/2025

WECC-0142 BAL-002-WECC-3—Contingency Reserve—Request to Retire
Executive Summary
This document supports and requests full retirement of WECC Regional Reliability Standard (RRS)
BAL-002-WECC-3, Contingency Reserve.
In FERC Order No. 672, when considering approval of RRSs, FERC agreed to accept two kinds of
regional differences: (1) a regional difference that is more stringent than the continent-wide Reliability
Standard, including a regional difference that addresses matters that the continent-wide Reliability
Standard does not; and (2) an RRS that is necessitated by a physical difference in the Bulk-Power
System. 1
Order 672 also provides authority to retire an RRS.
Since the start of BAL-002-WECC-3 and its predecessors (2007), the original standard and each
subsequent iteration have continued as more stringent than the continent-wide equivalent, NERC BAL002-X, Disturbance Control Standard. Among other things, WECC’s BAL-002-WECC has always
required most WECC entities to hold more reserves than the continent-wide equivalent. Specifically,
BAL-002-WECC-3, Requirement R1.1.1 requires the applicable entity to hold the greater of, either the
amount of Contingency Reserve equal to the loss of the most severe single contingency or the amount
of Contingency Reserve equal to the sum of 3% of hourly integrated load and 3% of hourly integrated
generation.
Though Requirement R1.1.1 was approved in BAL-002-WECC-1, that approval was predicated on
distributing burden and the availability of deliverability. 2 There has never been a technical study
proving that holding reserves more than required under NERC BAL-002-X enhances the reliability of
the Western Interconnection.
By contrast, as variable generation is added to the Interconnection, there is increasing evidence that
holding excess reserves may be inhibiting reliability across the interconnection. FERC’s recent Order
901 echoes these concerns, addressing operational and performance concerns for variable resources.
Restated, within the Western Interconnection, applicable entities are holding more reserves than the
rest of the continent, even though there is no technical basis for doing so. In FERC Order 693, in which
NERC BAL-002-1 was first approved, at P341, FERC states:
341. We believe a continent-wide contingency reserves policy would assure [sic] that there are
adequate magnitude and frequency responsive contingency reserves in each Balancing

Order No. 672 at P 331. See also FERC Order 740, P 4 and P 23.
https://www.nerc.com/pa/Stand/Resources/Documents/FERC'S_Criteria_for_Approving_Reliability_Standards_fr
om_Order_672.pdf
2 FERC Order 740, Remand.
1

2

WECC-0142 BAL-002-WECC-3—Contingency Reserve—Request to Retire
Authority. This will improve performance so that no Balancing Authority will be doing less than
its fair share.” (Emphasis added.)
By extension, retiring BAL-002-WECC-3 in favor of NERC BAL-002-3, ensures that no Balancing
Authority will be doing more than its fair share.
Further, requiring Balancing Authorities to hold that excess may be inhibiting the integration and use
of variable generation. As a result, BAL-002-WECC-3 creates a mandated scenario in which reserves are
used inefficiently and withheld from the marketplace.

3

WECC-0142 BAL-002-WECC-3—Contingency Reserve—Request to Retire

Table of Contents
Introduction .............................................................................................................................................................5
Standard of Review ................................................................................................................................................6
Procedural History..................................................................................................................................................7
Development History (Pre-1996 to 2024) ............................................................................................................8
Structural Overview of BAL-002-WECC-3 ....................................................................................................... 11
Purpose ............................................................................................................................................................... 11
Applicability ...................................................................................................................................................... 11
Requirements ..................................................................................................................................................... 11
Requirement R1 ............................................................................................................................................. 11
Requirement R2 ............................................................................................................................................. 11
Requirement R3 ............................................................................................................................................. 12
Requirement R4 ............................................................................................................................................. 12
Reliability will be Maintained........................................................................................................................... 13
Vital Public Interests will be Enhanced .......................................................................................................... 18
Market Timing Issues ....................................................................................................................................... 18
Capacity Could be Better Utilized than Simply Holding Reserve .............................................................20
Conclusion ............................................................................................................................................................. 22

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WECC-0142 BAL-002-WECC-3—Contingency Reserve—Request to Retire

Introduction
Per the Standard Authorization Request (SAR) for WECC-0142, 3 this document explores the full
retirement of WECC RRS BAL-002-WECC-3, Contingency Reserve.
The following will show that, if the standard is retired, reliability will continue to be maintained
through NERC BAL-002-3, and may be enhanced as resources being held for contingency reserves may
be used more efficiently to support variable generation.
By retiring BAL-002-WECC-3 in favor of NERC BAL-002-3:
•

Dispatchable resources can be used to support variable generation, addressing issues raised by
FERC in Order 901.

•

A more efficient use of resources should negate any current negative impacts on the market,
thereby enhancing vital public interests.

As the Procedural History and Development History sections note, BAL-002-WECC-3 is an evolution of
pre-standards originating in the 1990s. Never during the estimated 30 years of its existence has there
been a technical justification for the values and procedures required in the standard. Rather, the stated
values and procedures are the result of generalized negotiations taking place between the parties.
Because these values and procedures are negotiated, the content of BAL-002-WECC-3 is the lowest
common denominator and does not meet the requirements of FERC Order 672. 4
Because BAL-002-WECC-2a, Contingency Reserve, Request to Retire Requirement R2 provided the
technical support for retiring Requirement R2, arguments in that filing are not revisited here. 5

See WECC-0142 BAL-002-WECC-3, Contingency Reserve, Request to Retire, home page, at the SAR accordion.
FERC Order 672, P329 and P330.
5 Approved by the NERC Board of Trustees on August 15, 2019, filed with FERC on September 9, 2019.
3
4

5

WECC-0142 BAL-002-WECC-3—Contingency Reserve—Request to Retire

Standard of Review
While the Commission may approve an RRS that is more stringent than a parallel continent-wide
standard, the Commission may also retire such a standard. 6
“While a Regional Entity may propose regional Reliability Standards that address specific,
unique regional conditions and circumstances, such regional Reliability Standards can be retired if
those justifications are no longer relevant. Accordingly, the Commission may approve retirement of
a more stringent regional requirement “if the Regional Entity demonstrates that the continentwide Reliability Standard is sufficient to ensure the reliability of that region.” 7 (Emphasis
added.)
In doing so, the Commission must give due weight to the technical expertise of a Regional Entity, like
WECC, that is organized on an interconnection-wide basis with respect to the regional differences
applicable to the Western Interconnection.
The technical qualifications of the subject matter experts compiling this paper are provided with this
filing, as presented and approved by the WECC Standards Committee (WSC).

The Commission approves regional differences proposed by Regional Entities, such as Regional Reliability
Standards and Variances, if the regional difference is just, reasonable, not unduly discriminatory or preferential,
and in the public interest. 16 U.S.C. § 824o(d)(2) and 18 C.F.R. § 39.5(a). (See also) Additionally, Commission
Order No. 672 requires further criteria for regional differences. A regional difference from a continent-wide
Reliability Standard must either be:
(1) more stringent than the continent-wide Reliability Standard, including a regional difference that addresses
matters that the continent-wide Reliability Standard does not; or is,
(2) necessitated by a physical difference in the Bulk-Power System.
7 Version One Regional Reliability Standard for Resource and Demand Balancing,
Order No. 740, 75 FR 65964 (Oct. 27, 2010), 133 FERC ¶ 61,063, P 30 (2010). See also: FERC, 18 CFR Part 40, Docket
No. RM19-20-000, WECC Regional Reliability Standard BAL-002-WECC-3 (Contingency Reserve), p.5
6

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WECC-0142 BAL-002-WECC-3—Contingency Reserve—Request to Retire

Procedural History
In 1996, the Western Systems Coordinating Council (WSCC) 8 adopted the WSCC Reliability Criteria,
Minimum Operating Reliability Criteria (MORC). The MORC prescribed levels of reserves that became
BAL-002-WECC-3, effective 2021.
In 1999, the MORC became the WECC Reliability Management System (RMS), a contract-based system
of accountability that pre-dated mandatory standards.
As the industry approached the onset of mandatory standards (2007) and memorialization of legacy
operating practices, the content of the RMS was adapted and approved as BAL-STD-002-0, Operating
Reserves (2007). That standard was an attempt to translate the substantive content of the RMS into the
sought-after NERC/FERC format of today’s reliability standards. The content was accepted “as is” with
its origins in the 1996 MORC; albeit, the early standard was remanded for remediation, largely on
format and structural grounds.
In 2013, FERC accepted remediations to BAL-002-WECC-2.
In 2017, an interpretation was added (BAL-002-WECC-2a) and later incorporated into BAL-002-WECC3, in which Requirement R2 was approved for retirement, with an effective date of August 15, 2019.
In 2025, the Western Interconnection still adheres to similar levels of reserves as it did in 1996. This
means that, for over 28 years, the Western Interconnection has held more reserves than the rest of the
continent (NERC BAL-002-3) even though there has never been technical justification to do so.

The Western Systems Coordinating Council (WSCC) was formed in 1967 by 40 power systems to coordinate the
planning and operations of the electric system in western North America. The WSCC's goal was to provide
reliable power to the public.

8

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WECC-0142 BAL-002-WECC-3—Contingency Reserve—Request to Retire

Development History (Before 1996 to 2024)
Before 1996, members of the WSCC voluntarily operated the Western Interconnection according to the
MORC. 9 Although the MORC contained provisions for generation control, generation performance,
and Contingency Reserve, the MORC provided no technical support for the reserve thresholds and
characteristics it set. 10 Rather, the operating thresholds were established by negotiation—not technical
analysis. If this approach were adopted today, FERC would likely deny approval of the standard as
contrary to FERC Order 672, P329. 11
In July and August of 1996, the Western Interconnection experienced two widespread outages resulting
from improper vegetation management. The resulting outage reports 12 13 made several
recommendations that would later be adopted in the 1999 WECC RMS. 14 15 The WECC Operating
Committee’s recommendation produced portions of the RMS that later evolved into WECC Standard
BAL-STD-002-0, Operating Reserves and, ultimately, BAL-002-WECC-3. Like the other initial

MORC, Maintenance Coordination: 1. Sharing information. The security and reliability of the interconnected
power system depends upon periodic inspection and adequate maintenance of generators, transmission lines and
associated equipment, control equipment, communication equipment, relaying equipment, and other system
facilities. Entities and coordinated groups of entities must establish procedures and responsibility for
disseminating information on scheduled outages and for coordinating scheduled outages of major facilities which
affect the security and reliability of the interconnected power system.
10 Minimum Operating Reliability Criterion, Section 1, Generation Control and Performance
11 FERC Order 672. P329. The proposed Reliability Standard must not simply reflect a compromise in the ERO’s
Reliability Standard development process based on the least effective North American practice—the so‐called
“lowest common denominator”—if such practice does not adequately protect Bulk‐Power System reliability.
Although the Commission will give due weight to the technical expertise of the ERO, we will not hesitate to
remand a proposed Reliability Standard if we are convinced it is not adequate to protect reliability.
12 The outage reports are available upon request. Western Systems Coordinating Council (WSCC) Disturbance
Report for the Power System Outage that Occurred on the Western Interconnection August 10, 1996, as approved
by the WSCC Operations Committee on October 18, 1996
13 “f. The WSCC Operations Committee shall assess whether the levels and allocation of operating reserves
contributed to the severity of this disturbance and implement corrective measures as appropriate.” Western
System Coordinating Council Disturbance Report, For the Power System Outages that Occurred on the Western
Interconnection on 2 JUL 1996. Approved by the WSCC Operations Committee on September 19, 1996. RMS
Outage Report, page 14.
14 The RMS was approved 1 SEP 1999. WECC Comment Report – WECC Tier 1- RMS Standard – (BAL-STD-002-0)
Question 4, Attachment 2, page 9.
15 “The majority of these standards were specifically developed to address and mitigate main causes of the two
major system outages that occurred in the Western Interconnection in July and August of 1996.” Agenda Item 3,
Board of Trustees Meeting, March 12, 2007, page 4
9

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WECC-0142 BAL-002-WECC-3—Contingency Reserve—Request to Retire
standards, the language of the original standard was a translation of the language contained in the
RMS. 16
In March 1997, noting that federal remedial legislation could take years to enact, the WSCC trustees
created the WSCC RMS Policy Group 17 establishing a contract-based operational system known as the
RMS. 18 19 In establishing the RMS, the WSCC RMS Policy Group reviewed all NERC and WECC
reliability criteria, identified specific criteria deemed critical for reliability management, then moved
those criteria into the RMS through a three-phase implementation plan. 20
On April 14, 1999, FERC asserted jurisdiction over the RMS.
Between September 1998 and February 2000 (phase two of the three-phase RMS implementation), the
WSCC turned the content of the RMS into the first mandatory reliability standards (aka Version Zero,
2007). BAL-SDT-002-0, Contingency Reserve was part of that translation.
On December 22, 2006, WECC submitted a request to NERC to approve, and send to FERC for
approval, eight proposed RRSs. WECC referred to the eight proposed standards as its Tier One

WECC states that the proposed regional Reliability Standards, which are exact translations of existing regional
criteria, either address matters not addressed in the Commission-approved ERO Reliability Standards or contain
more stringent requirements than the ERO standards. (FERC accepted Tier One standards evolving from the
RMS. AKA: Tier One Order.) FERC, 119 FERC ¶ 61,260 United States of America, Federal Energy Regulatory
Commission, Order Approving Regional Reliability Standards for the Western Interconnection and Directing
Modifications (Issued June 8, 2007), page 19.

16

Following the enactment of EPAct 2005 and the establishment of mandatory Reliability Standards applicable to
all owners, operators, and users of the BPS, WECC sought to translate certain of its existing practices under its
RMS reliability criteria into regional Reliability Standards to supplement the continent-wide Reliability Standards
the Commission approved in Order No. 693. To that end, WECC established a task force to identify criteria in the
RMS that should be binding on all BPS users, owners, and operators in the Western Interconnection, not just the
Transmission Operators subject to the RMS. The task force chose eight of the identified criteria, which had the
highest priority and could be implemented in the near term for translation into regional Reliability Standards.
United States of America Before the Federal Energy Regulatory Commission, North American Electric Reliability
Corporation (NERC), Docket No. RM16-10-000, Supplemental Information for Petition of the NERC and WECC
for Approval of retirement of Regional Reliability Standard TOP-007-WECC-1a, page 5.

17

18

Hearing

Electric Reliability Corporation, Helping Owners, Operators, and Users of the Bulk Power System Assure
Reliability and Security for More Than 50 Years, By David Nevius, Senior Vice President 1979–2012, Page 40-41.

19

20

Hearing

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WECC-0142 BAL-002-WECC-3—Contingency Reserve—Request to Retire
standards originating from the RMS because the proposed standards were translations of standards
that were already mandatory within the Western Interconnection as part of the RMS. 21
Those eight standards—that included Tier One WECC-BAL-STD-002-0 (Operating Reserves)—were
near-exact translations of existing WECC criteria that FERC earlier accepted as part of the WECC RMS
program. 22 Because the content was a near-exact translation, the format did not match that required by
NERC/FERC. This would later lead to a remand of BAL-002-WECC-1 to ensure conformity.
On January 9, 2007, NERC provided WECC with a report of its preliminary findings about the request
from December 22, 2006, and provided WECC with a list of required remediations. 23 The request
largely addressed styles, formats, and corrections to compliance sections. The NERC Board of Trustees
approved the Tier One request subject to remediation and sent the eight proposed standards to FERC
with a request for approval.
In June 2007, FERC approved WECC’s submittal of eight reliability-crucial Tier One standards, thereby
transitioning from the RMS system to that of FERC-approved NERC Reliability Standards. 24 Although
earlier versions lacked technical support, FERC agreed with
“WECC, WIRAB [Western Interconnection Regional Advisory Board] and NERC that
approval of [WECC’s early BAL] under section 215 would enhance reliability in the
Western Interconnection by making WECC’s current practices binding on all relevant
entities in the region and by strengthening WECC’s compliance and enforcement
authority.” 25

North American Electric Reliability Corporation, Docket No. RR07-___-000, III. BACKGROUND ON THE
DEVELOPMENT OF THE WECC REGIONAL RELIABILITY STANDARDS, Debra A. Palmer of Schiff/Hardin
(1666 K STREET N.W., SUITE 300, WASHINGTON, DC 20006) on March 26, 2007.
22 Loc. Cit. IV. Overview of the Proposed WECC Regional Reliability Standards, page 6.
23 NERC DECISION APPROVING, WITH CONDITIONS, RELIABILITY STANDARDS PROPOSED BY
WESTERN ELECTRICITY COORDINATING COUNCIL, page 2. (Approved by Board of Trustees March 12,
2007)
24FERC Order Approving Regional Reliability Standards for the Western Interconnection and Directing
Modifications, Docket No. RR07-11-000, (Issued June 8, 2007)
25 Tier One Order, p. 43. See also, “The proposed regional Reliability Standards would make eight of those RMS
criteria binding on the applicable subset of users, owners and operators of the Bulk-Power System in the United
States portion of the Western Interconnection, as identified in each proposed standard. The regional Reliability
Standards would supplement rather than replace the Commission-approved Reliability Standards developed by
the ERO that will take effect in June 2007. Tier One, p. 10.
21

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WECC-0142 BAL-002-WECC-3—Contingency Reserve—Request to Retire

Structural Overview of BAL-002-WECC-3
Purpose
The Purpose of currently effective RRS BAL-002-WECC-3—Contingency Reserve is to provide an RRS
specifying “the quantity and types of Contingency Reserve required to ensure reliability under normal
and abnormal conditions.” 26
The NERC Glossary defines Contingency Reserve as:
“The provision of capacity that may be deployed by the Balancing Authority to respond to a Balancing
Contingency Event and other contingency requirements (such as Energy Emergency Alerts as specified
in the associated EOP standard). A Balancing Authority may include in its restoration of Contingency
Reserve readiness to reduce Firm Demand and include it if, and only if, the Balancing Authority:
•

is experiencing a Reliability Coordinator declared Energy Emergency Alert level and is utilizing
its Contingency Reserve to mitigate an operating emergency in accordance with its emergency
Operating Plan.

•

is utilizing its Contingency Reserve to mitigate an operating emergency in accordance with its
emergency Operating Plan.”

Applicability
BAL-002-WECC-3 applies to Balancing Authorities (BA), unless the BA is a member of a Reserve
Sharing Group (RSG), in which case the RSG becomes the applicable entity.

Requirements
The standard consists of four requirements.
Requirement R1
•

Provides that each BA and RSG must maintain a minimum amount of Contingency Reserve,
except within the first sixty minutes following an event requiring the activation of Contingency
Reserves, and that the Contingency Reserve must consist of any combination of a list of
specified reserve types.

Requirement R2
•

26

Reserved. Retired, subject to cyclical field tests.

BAL-002-WECC-3, Contingency Reserve, Purpose.

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WECC-0142 BAL-002-WECC-3—Contingency Reserve—Request to Retire
Requirement R3
•

Each Sink BA and RSG must maintain an amount of Operating Reserve, in addition to the
minimum Contingency Reserve in Requirement R1, equal to the amount of Operating Reserve–
Supplemental for any Interchange Transaction designated as part of the Source Balancing
Authority’s Operating Reserve–Supplemental or source Reserve Sharing Group’s Operating
Reserve–Supplemental, except within the first sixty minutes following an event requiring the
activation of Contingency Reserve.

Requirement R4
•

Each Source BA and RSG must maintain an amount of Operating Reserve, in addition to the
minimum Contingency Reserve amounts identified in Requirement R1, equal to the amount
and type of Operating Reserves for any Operating Reserve transactions for which it is the
Source BA or RSG.

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WECC-0142 BAL-002-WECC-3—Contingency Reserve—Request to Retire

Reliability will be Maintained
Upon retirement of BAL-002-WECC-3, reliability will be maintained by NERC BAL-002-3, Disturbance
Control Standard—Contingency Reserve for Recovery from a Balancing Contingency Event, reinforced
by the enhanced availability of resources currently unavailable under BAL-002-WECC-3.
Replacing BAL-002-WECC-3 with NERC BAL-002-3 Mitigates Reliability Gaps associated
with Variable Generation
As highlighted by FERC in its Order 901, with the growing amount of variable generation replacing
more responsive and dispatchable resources, the industry faces the dilemma of how to support these
new resources. 27 Unlike traditional resources, much of the new variable generation cannot be quickly
dispatched, thus creating a gap in reliability. FERC acknowledged that gap, noting that neither
business as usual nor existing reliability standards will remedy this concern. Finally, FERC also
recognizes the value that steps taken must apply on a continent-wide basis. 28
Replacing BAL-002-WECC-3 with the continent-wide NERC BAL-002-3 takes immediate steps towards
meeting FERC’s concerns.
In Order 901, FERC states:
“[W]e continue to find that as the resource mix trends towards higher penetrations of IBRs, the
need to reliably integrate these resources into the Bulk-Power System is expected to grow, and
that the currently effective Reliability Standards do not adequately address IBR reliability risks.
The continuing risks that the increasing penetration of IBRs pose to the reliable operation of the BulkPower System underscore the need for mandatory Reliability Standards to address these issues on a
nationwide basis.” (Emphasis added.) Order 901, P24.
When BAL-002-WECC-3 is retired and replaced with NERC BAL-002-3, the amount and type of
reserves required to be held back within the Western Interconnection will decrease. That frees those
resources to be plied against load. Within the Western Interconnection, a vast majority of these
sequestered resources are immediately dispatchable (such as hydro), thus serving as the perfect
resource to match the less predictable response of variable generation.

FERC Order 901, P11-15, 185 FERC ¶ 61,042, United States of America, Federal Energy Regulatory Commission
(FERC), 18 CFR Part 40, Docket No. RM22-12-000; Reliability Standards to Address Inverter-Based Resources,
October 19, 2023. Hereafter: Order 901
28 Order 901, P24.
27

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WECC-0142 BAL-002-WECC-3—Contingency Reserve—Request to Retire
By making these dispatchable resources more operationally available, the secondary benefits may be to
bolster the supply of generation to the market. This potential secondary benefit directly addresses vital
public interests. 29
Dispatchable Resources Contribute Significantly to Essential Reliability Services (ERS) 30
ERSs consist of frequency control, ramping capability, and voltage control.
Frequency control is necessary because the electric grid is designed to operate at a frequency of 60 hertz
(Hz). Deviations from 60 Hz can have destructive effects on generators, motors, and equipment of all
sizes and types. It is critical to maintain and restore frequency after a disturbance such as the loss of
generation. This requires an instantaneous (inertial) response from some resources and a fast response
from other resources to slow the rate of fall during the arresting period, a fast increase in power output
during the rebound period to stabilize the frequency, and a more prolonged contribution of additional
power to compensate for lost resources and bring system frequency back to the normal level. Two
NERC Reliability Standards address this:
•

BAL-002-3 Disturbance Control Standard—Contingency Reserve from a Balancing Contingency
Event

•

BAL-003-2 Frequency Response and Frequency Bias Setting

Adequate ramping capability (the ability to match load and generation at all times) is necessary to
maintain system frequency. Changes to the generation mix or the system operator’s ability to adjust
resource output can impact the ability of the operator to keep the system in balance. NERC Reliability
Standard BAL-001-2 (Real Power Balancing Control Performance) addresses this issue.
Voltage must be controlled to protect system reliability and move power where it is needed in both
normal operations and following a disturbance. Voltage issues tend to be local in nature, such as in
sub-areas of the transmission and distribution systems. Reactive power is needed to keep electricity
flowing and maintain necessary voltage levels. Several NERC Reliability Standards address voltage
control.
Restated, replacing BAL-002-WECC-3 with NERC BAL-002-3 frees dispatchable resources to address
FERC-identified reliability gaps created by variable generation, and may bolster vital public interests.

“335. Finally, we understand that at times development of a proposed Reliability Standard may require that a
particular reliability goal must be balanced against other vital public interests, such as environmental, social, and
other goals. We expect the ERO to explain any such balancing in its application for approval of a proposed
Reliability Standard. “ (Emphasis added.) Order 693, P35.
30 “Essential Reliability Services (ERS) are the elemental ‘reliability building blocks’ from resources (generation
and demand) necessary to maintain Bulk Power System (BPS) reliability.” NERC ERS Task Force – Scope – 2014.
29

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WECC-0142 BAL-002-WECC-3—Contingency Reserve—Request to Retire
Because adequate levels of reserves are established in NERC BAL-002-3, and supported by BAL-003-2,
BAL-002-WECC-3, Requirements R1 through R4 are not needed.
Replacing BAL-002-WECC-3 With NERC BAL-002-3 Provides Sufficient Reserves at a
Continent-Wide Level
In the earliest stages of the Western Interconnection’s strides to establish adequate Contingency
Reserves, the applicable entity’s reserves were established by BAL-STD-002-0, Operating Reserves, at
5% of hydro generation and 7% thermal generation (50% spinning and 50% non-spinning). 31 These
thresholds were not technically supported; they were the result of contractual negotiations. Today,
such a standard would likely not be approved by FERC as violative of the principles established in
FERC Order 672. (See foot note 2.)
As BAL-STD-0-2 was replaced with later iterations of that standard, the result was today’s BAL-002WECC-3, in which the Responsible Entity’s reserves are set at:
R1.1.1 “The greater of either:
•

The amount of Contingency Reserve equal to the loss of the most severe single contingency; 32
(or)

•

The amount of Contingency Reserve equal to the sum of three percent of hourly integrated
Load plus three percent of hourly integrated generation.”

Bullet one of BAL-002-WECC-3 describes the Most Severe Single Contingency, or MSSC.
The MSSC ensures that all entities can recover Area Control Error (ACE) within 15 minutes. The MSSC
serves as the upper Contingency Reserve threshold for all interconnections, except the Western
Interconnection. Within the Western Interconnection, the levels of reserve set by BAL-002-WECC-3 can
exceed that of the rest of the continent that is protected by FERC-approved BAL-002-3. As a result, the
Western Interconnection carries an excess of reserve that exacerbates concerns raised by FERC in Order
901 wherein FERC addresses the need for continent-wide standards to backstop the operational
performance of variable generation. Comparing NERC BAL-002-3 with BAL-002-WECC-3 illustrates
this outcome.
NERC BAL-002-3 states that the BA and the RSG are not subject to compliance with BAL-002-3, R1 for
multiple events that exceed the MSSC. NERC BAL-002-3 requires the applicable entity to deploy
Contingency Reserve up to its MSSC; however, it does not require Contingency Reserve deployment
beyond MSSC.

See Attachment - Transition from 5-7 to 3-3, as described in 2005 by Merrill Schultz; see also Attachment History of WECC Reserve 5-7 Spin Merrill Schultz, March 3, 2005; see also BAL-STD-002-0, Operating Reserves.
32 Also known as the Most Severe Single Contingency (MSSC).
31

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WECC-0142 BAL-002-WECC-3—Contingency Reserve—Request to Retire
By contrast, BAL-002-WECC-3 requires the applicable entity to maintain a level of Contingency
Reserves exceeding that required under NERC BAL-002-3, as approved by FERC. Specifically, BAL-002WECC-3, Requirement R1 requires the applicable entity to carry reserves that equal or exceed the
entity’s MSSC—beyond that required by BAL-002-3 that adequately serves the balance of the continent.
Among other things, this means these valuable dispatchable resources in excess of the MSSC cannot be
used to meet FERC’s goal of backstopping variable resources as identified in FERC Order 901.
While the application of BAL-002-3 could free resources to enhance reliability, the application of BAL002-WECC-3 can inhibit reliability when resources are withheld that could otherwise serve load and
backstop variable resources.
For example:
Using historical data from January 2020 - May 2024, comparison of the hourly Contingency Reserve
Requirement (calculated using 3% generation and 3% load) to the Most Severe Single Contingency
(MSSC), the results identified there was more than 5,000 MW of capacity available during the
summertime peak hours and between 2,000-2,500 MW during the remaining hours of the year. See
figure below.

Figure 1: Reserves in excess of MSSC

The Shortened Execution Time of BAL-002-WECC-3 Inhibits Reliability Due to Market
Rules in the Western Interconnection
BAL-002-WECC-3, Requirements R3 and R4 require the applicable entity to restore Contingency
Reserve within 60 minutes of the initiating event. By contrast, BAL-002-3 requires the applicable entity
to achieve the same task in 105 minutes. As a result, BAL-002-WECC-3 requires the performance of the
same task 45 minutes earlier than its continent-wide counterpart. This shortened period inhibits
reliability in that it forces the applicable entities into transactions agreed upon during an arbitrarily
shortened time window. Like BAL-002-3, Requirement R1., there is no technical support suggesting

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WECC-0142 BAL-002-WECC-3—Contingency Reserve—Request to Retire
that rushing this transaction enhances reliability—yet it remains in force 28 years after its inception,
still lacking any technical support.
Further, the restoration of reserves in a 60-minute timeframe is restrictive on the entity’s ability to
secure additional resources within the established business practices in the region. The NERC Standard
of up to 105 minutes (90 minutes after the 15 minutes Contingency Recovery Period) after the event has
less commercial impact and is acceptable from both a commercial standpoint as well as an operational
standpoint.
The WECC requirement of 60 minutes from start of a DCS event restricts the deficient entity from
rescheduling resources to replace those that were lost during the event. Western market practices
require schedules to be submitted and approved well in advance to ensure reliability, and once the
schedule windows close, it is difficult to make last-minute changes. Before markets, when transactions
were bilateral, a recovery of generation resources was more flexible, and could be more quickly
executed.
The NERC BAL-002-3 Contingency Reserve Restoration Period of up to 105 minutes allows applicable
entities to use normal market scheduling practices to replace lost generation. FERC’s approval of NERC
BAL-002-3 shows its belief that the NERC standard of 105 minutes (90 plus 15) is adequate and does
not degrade reliability.
In attempting to meet the 60-minute restoration requirement, the applicable entity has two options.
First, the BA must carry significantly more Contingency Reserve than is required to maintain an
adequate level of reliability, or second, be prepared to enter an Energy Emergency Alert 3 which allows
the BA to deploy Contingency Reserves to serve load. By definition, entering into an Energy
Emergency Alert is an indication of reduced reliability. Given normal scheduling practices, a 90-minute
restoration time allows a Responsible Entity to restore Contingency Reserve using normal established
market scheduling practices.
In addition, many entities own BES equipment in more than one interconnection. Having a single
standard enhances these entities’ ability to stay in compliance with the standard using consistent
business practices across the interconnections.
Reserve Thresholds do Not Reflect Resource Mix
Due to the changing resource mix and the proliferation of renewable generation, battery storage, and
retirements of conventional synchronous generation, resource adequacy has become a serious concern.
The BAL-002-WECC standard unnecessarily ties up significant generation which is dispatchable,
frequency responsive and fast ramping. Generation that could be used to meet ramps, follow variable
resources, or simply meet expected loads, is committed to contingency reserve capacity that is not
available to serve load. For example, Western Power Pool’s Northwest Power Pool Reserve Sharing
Group Northwest-Montana zone typically has a 1,200 MW MSSC, yet routinely has over 3,000 MW of
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WECC-0142 BAL-002-WECC-3—Contingency Reserve—Request to Retire
reserves being held under the 3/3 requirement. That available capacity, usually in excess 1,800 MW,
could be used to meet other reliability related services obligations. The existing 3/3 contingency reserve
requirement results in the construction of at least 1800 MW of excess generation in the NorthwestMontana zone. The ability to use this generation capacity exceeding the MSSC will also allow entities to
efficiently operate their facilities. Idled excess capacity will be reduced and productive generation
increased.
Under NERC standard NERC BAL-002-3, the Eastern, Texas and Quebec Interconnections operate
without the additional reserve requirement (3% load and 3% generation), and they are allowed to
restore their reserves within 90 minutes. The changing market structure in the Western Interconnection
has made it difficult to fully restore the required reserves within 60 minutes due to market scheduling
timelines. This can lead to implementation of emergency procedures, typically Energy Emergency Alert
3 conditions, due to an energy shortfall precipitated by the 60-minute recovery period. When the
Western markets were mostly bilateral, the 60-minute recovery was consistent with energy scheduling
protocols. Market integration has altered energy scheduling protocols making it very difficult to
modify schedules within 60 minutes of a generation contingency. For these reasons BAL-002-WECC-3
has become obsolete, while not enhancing reliability.
Reserves are unused or unloaded generation that are in a state of readiness in case there is sudden loss
of loaded generation. When reserves are held above the MSSC, as they are in the Western
Interconnection, excess capacity must be built that has no other reliability benefit. Every energy
customer in the West absorbs this excess cost. Retirement of BAL-002-WECC-3 reallocates these excess
resources to the benefit of the interconnection in the form of dispatchable, responsive, and available
resources to reliably integrate future variable resources, such as wind, solar, and other renewable
resources.

Vital Public Interests will be Enhanced 33 34
Market Timing Issues
The emergence of organized markets in WECC, since the inception of BAL-002-WECC-1 has brought a
new dynamic in the timing and means by which the reserves are procured. The number of participants
in the California ISO Energy Imbalance Market (AKA: Western Energy Imbalance Market, or WEIM)

“Finally, we understand that at times development of a proposed Reliability Standard may require that a
particular reliability goal must be balanced against other vital public interests, such as environmental, social, and
other goals. We expect the ERO to explain any such balancing in its application for approval of a proposed
Reliability Standard.” FERC Order No. 672 at P 335.
34 “The proposed Reliability Standard does not necessarily have to reflect the optimal method, or “best practice,”
for achieving its reliability goal without regard to implementation cost or historical regional infrastructure design.
It should however achieve its reliability goal effectively and efficiently.” FERC Order No. 672 at P 328.
33

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WECC-0142 BAL-002-WECC-3—Contingency Reserve—Request to Retire
has grown significantly in the past several years. CAISO EIM market rules require a participating BA to
balance its resources and loads 75 minutes before the next operating hour (T-75). Failure to do this can
result in financial penalties to the participating BA. This rule has had the effect of discouraging any
bilateral energy trading after T-75 and does not align well with a 60-minute reserve recovery time limit.
No bilateral trading for replacement energy reserve is possible for the next operational hour because
participating WEIM BAs cannot participate in trades within T-75.
This leaves the contingent BA in a resource short position when the 60-minute contingency restoration
time expires. At this point, the contingent BA must activate emergency operating procedures up to
asking the Reliability Coordinator to declare an EEA3, including load shedding to balance the
contingent BA. By extending the contingency restoration time to 105 minutes (15-minute recovery plus
90-minute restoration), the contingent BA has at least 30 minutes to arrange replacement energy in a
bilateral manner from other BAs or schedule their own resource in the WEIM. The additional
contingency reserve recovery time allows the contingent BA to make orderly and planned adjustments
and continue to serve firm load without the implementation of emergency operating procedures, up to
and including shedding firm load.
FERC and the industry have determined that 90 minutes from the end of the recovery period (up to 15
minutes) is sufficient to maintain an adequate level of reliability. The shorter restoration period in the
WECC creates artificial reliability issues as the applicable entity tries to rebalance supply and demand
in an arbitrarily shorter period than that required in the NERC BAL-002-3.
To give a clear understanding of the impact of either option, the following example is provided.
Assume the NWPP RSG’s MSSC is approximately 1,200 MW. Under BAL-002-WECC-3, the NWPP RSG
would normally carry approximately 2,200-4,000 MW of Contingency Reserves depending on the time
of year. Assuming the MSSC occurs, the NWPP RSG would activate 1,200 MW of its reserves and
restore the ACE to the pre-event level. Members now have approximately 60 minutes to restore 1,200
MW of reserves while still carrying more than 1,000–2,800 MW, which is greater than the MSSC,
assuming it was not reduced with the loss of the 1,180 MW event. See figure below.

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WECC-0142 BAL-002-WECC-3—Contingency Reserve—Request to Retire

Figure 2: Reserves in excess of MSSC; January 1, 2020, through May 1, 2024

As discussed earlier, due to market rules related to the WEIM in which most entities are taking part,
new resources cannot be added to an entity’s reserves for the next hour (minimum time to add a
resource under the WEIM (75 minutes), or other emerging markets. If a resource is not already in the
WEIM, it cannot count toward the reserves needed. So, an entity must have already been carrying
reserves greater than required under the WECC standard, or it must reduce load to balance its
resources and loads including reserves. (It can be argued that by reducing loads, you are putting the
interconnection at greater risk because you have removed one available resource, the load, from being
an option for the next event.) To avoid the declaration of an EEA, the NWPP would need to carry an
additional 1,000 MW above the required reserves or declare an EEA any time the reserves need to be
restored within 60 minutes of the event.
When entities withhold extra reserves to avoid the EEA, this paradigm keeps 2,500 to 4,000 MW from
serving load due to the WECC current standard, which has no technical merit, as compared to the
NERC Standard. These additional resources could be used to help integrate more inverter-based
resources and serve loads more efficiently if it were available for load service.
Entering an Energy Emergency Alert indicates reduced reliability. Given normal scheduling practices,
which require bilateral schedules to be completed and approved 75 minutes before the hour, a 60minute restoration time does not allow adequate time for a Responsible Entity to restore Contingency
Reserve in less than 60 minutes from the initiating event, potentially resulting in an Energy Emergency
Alert situation.

Capacity Could be Better Used than Simply Holding Reserve
FERC and the industry have determined that the amount of Contingency Reserve needed to maintain
an adequate level of reliability is the amount of Contingency Reserve needed to replace the MSSC
resource. Holding Contingency Reserve more than MSSC precludes using operating reserve for other
purposes, particularly load and resource balancing in real-time. As the grid transitions from

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WECC-0142 BAL-002-WECC-3—Contingency Reserve—Request to Retire
conventional synchronous generation to more variable renewable resources, increasing capacity will be
needed to manage the variability and faster ramping requirement of these resources. Allocating
reserves in excess of that needed to maintain an adequate level of reliability, or MSSC, ultimately
detracts from reliability.

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WECC-0142 BAL-002-WECC-3—Contingency Reserve—Request to Retire

Conclusion
Retirement of BAL-002-WECC-3 Contingency Reserve would reduce required reserves in WECC
without diminishing the ability to meet the deployment requirement. Freeing up reserves from the
Contingency Reserve requirement would increase the resources available to manage variable resources
and accommodate increased renewable resource integration.
The existing BAL-002-WECC-3 Contingency Reserve sets a BA’s or RSG’s Contingency Reserve
requirement to the greater of the MSSC or 3% of the applicable entity’s generation and 3% of its load.
This 3/3 requirement exceeds MSSC for most responsible entities.
By contrast, NERC Standard BAL-002-3 Disturbance Control Standard—Contingency Reserve for
Recovery from a Balancing Contingency Event, Requirement R1.3.2 states that the BA/RSG is not
subject to compliance with Requirement R1 for multiple events that exceed the MSSC. NERC BAL-0023 requires the applicable entity to deploy Contingency Reserve up to the MSSC but does not require
Contingency Reserve deployment beyond the MSSC.
In BAL-002-3, FERC and the industry have determined that the amount of Contingency Reserve
needed to maintain an adequate level of reliability is the amount of Contingency Reserve needed to
replace the MSSC resource.
Holding Contingency Reserve more than MSSC precludes using operating reserve for other purposes,
particularly load and resource balancing in real time. As the grid transitions from conventional
synchronous generation to more variable renewable resources, increasing capacity will be needed to
manage the variability and faster ramping requirement of these resources. Allocating reserve in excess
of that needed to maintain an adequate level of reliability, or MSSC, ultimately detracts from reliability.
BAL-002-WECC-3 requires an applicable entity to restore Contingency Reserve within 60 minutes of
the initiating event (as opposed to up to 105 minutes in BAL-002-3), or 45 minutes sooner than required
by BAL-002-3. With respect to impacts to the time to restore Contingency Reserve, FERC and the
industry have determined that 90 minutes from the end of the recovery period (up to 15 minutes) is
sufficient to maintain an adequate level of reliability. By contrast, the 60-minute requirement within
BAL-002-WECC-3 creates potential reliability issues as an applicable entity tries to rebalance in an
arbitrarily shorter period than that required in the NERC BAL-002-3. In attempting to meet the 60minute restoration requirement, an applicable entity has two options. First, the BA must carry
significantly more Contingency Reserve than is required to maintain an adequate level of reliability, or
second, be prepared to enter an Energy Emergency Alert 3 and deploy Contingency Reserve to serve
load. Given normal scheduling practices, a 90-minute restoration time allows an applicable entity to
restore Contingency Reserve without employing emergency procedures.
Retirement of BAL-002-WECC-3 will enhance the reliable operation of the Western Interconnection by
allowing resources that are presently used for overprotecting above the MSSC to be available to meet
22

WECC-0142 BAL-002-WECC-3—Contingency Reserve—Request to Retire
the immediate balancing needs of the Interconnection. This will free those resources to be used as
needed in a rapidly changing system to maintain overall reliability.

23

Exhibit C
Summary of Development and Complete Record of
Development

Attachment E – Project Roadmap
WECC-0142 BAL-002-WECC-3 Request to Retire

Project Roadmap
Actions

1.

Standard Authorization Request (SAR) Filed

2.

WECC Standards Committee (WSC) approved the SAR

3.

Drafting Team (DT) Solicitation

4.

WSC approves a Drafting Team

5.

DT Meeting

6.

DT Meeting (Subset)

7.

DT Meeting (Subset)

8.

DT Meeting

9.

DT Meeting

10.

DT Meeting

11.

DT Meeting

12.

DT Meeting

13.

DT Meeting

14.

DT Meeting

15.

DT Meeting

16.

DT Meeting

17.

DT Meeting

Completed

August 14, 2020
October 22, 2020
November 5, 2020
December 8, 2020
March 16, 2021
March 31, 2021
April 14, 2021
April 28, 2021
May 26, 2021
June 21, 2021
June 30, 2021
July 23, 2024
August 22, 2024
September 19, 2024
October 3, 2024
October 10, 2024
October 24, 2024

E LECTRIC R ELIABILITY AND S ECURITY F OR THE W EST

18.

DT Meeting

19.

Posting 1 Open

20.

Posting 1 Closed

21.

DT Meeting

22.

WSC Approved for Ballot

23.

Ballot Pool Open

24.

Ballot Pool Closed

25.

Standards Briefing Open Meeting

26.

Ballot Open

27.

Ballot Closed

28.

Passed Ballot Pool Approval

29.
WSC Approved for WECC Board of Directors (Board)
Disposition
30.
WECC Board Approved for NERC/FERC Filing
31.

NERC 45-Day Comment – Open

32.

NERC 45-Day Comment – Closed

33.

DT Meeting

34.

NERC Board of Trustees Approved

A TTACHEMENT E – P ROJECT R OADMAP WECC-0142

November 7, 2024
November 15, 2024
January 15, 2025
January 21, 2025
March 6, 2025
April 14, 2025
April 28, 2025
April 30, 2025
May 1, 2025
May 15, 2025
May 15, 2025
May 21, 2025
June 11, 2025
TBD
TBD
TBD
TBD

2

Attachment A
Standard Authorization Request
WECC-0142 BAL-002-WECC-2a
Contingency Reserve
Request to Retire

Overview
This Standard Authorization Request (SAR) was: 1) received August 14, 2020, 2) deemed complete on
August 27, 2020, 3) input into the WECC SAR software on October 20, 2020, for WECC Standards
Committee (WSC) review on October 22, 2020.
This SAR can be reviewed in its originally submitted format on the WECC-0142 project page at the
Standard Authorization Request accordion.
If you have questions regarding this SAR, please contact W. Shannon Black at [email protected], (503)
307-5782.

Introduction
This project is a request to retire BAL-002-WECC-2 Contingency Reserve in its entirety.

Requester Information
Primary contact
•

First name:

ChaRee

•

Last name:

DiFabio

•

Email:

[email protected]

•

Phone:

(503) 445-1079

•

Organization name:

Northwest Power Pool Reserve Sharing Group

Alternate
•

First name:

Greg

•

Last name:

Park

•

Email:

[email protected]

•

Phone:

(503) 445-1089

1

Standard Authorization Request
WECC-0142 BAL-002-WECC-2a
Contingency Reserve
Request to Retire

Type of Request
This is a request to retire BAL-002-WECC-2a Contingency Reserve in its entirety.

Create, Modify, Retire or Review a Document
Requested Action (Select one)
•

This is a request to retire BAL-002-WECC-2a Contingency Reserve in its entirety.

Document Type (Select one)
•

WECC Regional Standard

Issue
This SAR is assigned WECC Tracking Number WECC-0142. It was deemed valid and complete on
August 27, 2020, and vetted by the WSC on October 22, 2020.
Retirement of BAL-002-WECC-2a Contingency Reserve would reduce required reserves in WECC
without diminishing the ability to meet the deployment requirement. Freeing up reserves from the
Contingency Reserve requirement would increase the resources available to manage variable resource
and accommodate increased renewable resource integration.
The existing WECC-0115 BAL-002-WECC-2a Contingency Reserve sets a Balancing Authority’s (BA) or
Reserve Sharing Groups’ (RSG) (Responsible Entity) Contingency Reserve requirement to the greater of
the Most Severe Single Contingency (MSSC) or 3% of Responsible Entity generation.
By contrast, NERC Standard BAL-002-3 Disturbance Control Standard—Contingency Reserve for
Recovery from a Balancing Contingency Event, Requirement R1.3.2 states that the BA or RSG is not
subject to compliance with Requirement R1 for multiple events that exceed the MSSC. NERC BAL-0023 requires the Responsible Entity to deploy Contingency Reserve up to the MSSC but does not require
Contingency Reserve deployment beyond the MSSC. BAL-002-WECC-2a requires a Responsible Entity
to maintain Contingency Reserve that equals or exceeds the MSSC. In a larger BA or RSG, the
summation of 3% of load plus 3% of generation exceeds the MSSC amount.
Requiring a Contingency Reserve capacity amount exceeding MSSC reduces the system capacity that is
available to meet other reliability needs of that BA or RSG or to assist others in the Western
Interconnection. As the interconnection resource mix transitions to a greater resource share provided
by renewable variable energy resources, this freed-up capacity could be used to provide real-time load
and resource balancing rather than being allocated to Contingency Reserve. At the same time,
Contingency reserve would be made available in sufficient quantity to meet any MSSC event and

2

Standard Authorization Request
WECC-0142 BAL-002-WECC-2a
Contingency Reserve
Request to Retire
preserve reliability of the interconnection for the unplanned loss of a resource. The history behind the
3% load and 3% generation (see attachment Transition from 5-7 to 3-3), which was receded by the 5%
hydro, 7% thermal (50% spin, 50% non-spin) was described in 2005 by Merrill Schultz, see attachment
History of WECC reserve 5-7 Spin Merrill Schultz 03032005, moved to the 3% load and 3% generation
to resolve inconsistency in the responsibility for reserves supporting interchange transactions and as a
consensus recognition that the 5% hydro and 7% thermal could be relaxed on frequency response
studies.
Proposed Remedy
Retirement of this Standard will allow a BA or RSG to allocate excess capacity to meet other reliability
needs in the BA, RSG, or the Western Interconnection.
FERC and the industry have determined that the amount of Contingency Reserve needed to maintain
an adequate level of reliability is the amount of Contingency Reserve needed to replace the MSSC
resource. Holding Contingency Reserve in excess of MSSC precludes using operating reserve for other
purposes, particularly load and resource balancing in real-time. As the grid transitions from
conventional synchronous generation to more variable renewable resources, increasing capacity will be
required to manage the variability and faster ramping requirement of these resources. Allocating
reserve in excess of that needed to maintain an adequate level of reliability (MSSC) ultimately detracts
from reliability .
BAL-002-WECC-2a requires a Responsible Entity to restore Contingency Reserve within 60 minutes of
the initiating event (as opposed to up to 105 minutes in BAL-002), or 45 minutes sooner than required
by BAL-002. With respect to impacts to the time to restore Contingency Reserve, FERC and the
industry have determined tat 90 minutes from the end of the recovery period (up to 15 minutes) is
sufficient to maintain an adequate level of reliability. This creates potential reliability issues as a
Responsible Entity attempts to rebalance in an arbitrarily shorter period than that required in the
NERC BAL-002. In attempting to meet the 60-minute restoration requirement, a Responsible Entity has
two options. First, the BA must carry significantly more Contingency Reserve than is required to
maintain an adequate level of reliability, or second, be prepared to enter an Emergency Alert 3 and
reduce load to restore Contingency Reserve. Entering into an Energy Emergency Alert indicates
reduced reliability. Given normal scheduling practices, a 90-minute restoration time allows a
Responsible Entity to restore Contingency Reserve in less than 60 minutes from the initiating event,
resulting in an Energy Emergency Alert situation.
In addition, many entities own BES equipment in more than one interconnection. Having a single
Standard helps these entities remain in compliance with the Standard.

3

Standard Authorization Request
WECC-0142 BAL-002-WECC-2a
Contingency Reserve
Request to Retire
Applicable Entities
•

Balancing Authority

•

Reserve Sharing Group

Detailed Description
Retire BAL-002-WECC-2a Contingency Reserve. The current Standard has four major differences from
BAL-002-3 Disturbance Control Standard—Contingency Reserve for Recovery from a Balancing
Contingency Event.
1) Contingency Reserve Requirement
a. BAL-002-3 requires the Responsible Entity to have Contingency Reserve equal to, or
greater than, the Responsible Entity’s MSSC.
b. BAL-002-WECC-2a requires the Responsible Entity to have Contingency Reserve equal
to, or greater than, the greater of: i) the Responsible Entity’s MSSC or, ii) the sum of 3%
of the hourly integrated load plus 3% of hourly integrated generation.
2) Spinning Reserve Requirement
a. BAL-002-3 does not have a Spinning Reserve requirement.
b. BAL-002-WECC-2a currently has a Spinning Reserve requirement of one half of total
Contingency Reserve obligation (currently under review by FERC for removal).
3) Reserve Restoration
a. BAL-002-3 requires reserve to be restored at the end of the Contingency Reserve
Restoration Period (a period not exceeding 90 minutes following the end of the
Contingency Event Recovery Period). The Contingency Event Recovery Period extends
15 minutes from the beginning of a Reportable Balancing Contingency Event.
b. BAL-002-WECC-2a requires restoration of Contingency Reserve within 60 minutes
following the event.
4) Operating Reserve Requirement modifications due to transactions
a. BAL-002-3 does not have requirements to modify Operating Reserve due to reserve
transactions with other entities.
b. BAL-002-WECC-2a requires Operating Reserve be held, in addition to minimum
Contingency Reserve requirements, for interchange Transactions that are designated as
part of the entity’s Operating Reserve—Supplemental.
Discussion
1) The MSSC is the reliability standard for all interconnections but the Western Interconnection.
This ensures that all entities can recover ACE for their MSSC within 15 minutes. Holding a
value greater than that (such as 3% generation and 3% load), which does not have any rigorous
4

Standard Authorization Request
WECC-0142 BAL-002-WECC-2a
Contingency Reserve
Request to Retire
study around it, does not enhance reliability of the interconnection. In fact, it decreases
reliability of the interconnection by allocating resources as Contingency Reserve that could be
used for other operational needs to maintain reliability. By requiring Contingency Reserve
beyond MSSC and in excess of what is necessary to maintain an adequate level of reliability,
additional resources are needed to maintain reliability for other needs, such as variability of
resources and fast ramping.
2) The spinning reserve requirement (R2) will no longer be part of the standard by the time this
SAR is addressed.
3) With respect to the time to restore Contingency Reserve, FERC and the industry have
determined that 90 minutes from the end of the recovery period (up to 15 minutes) is sufficient
to maintain an adequate level of reliability. BAL-002-WECC-2a requires a Responsible Entity to
restore Contingency Reserve within 60 minutes of the initiating event (as opposed to up to 105
minutes in BAL-002), or 45 minutes sooner. This creates potential reliability issues as a
Responsible Entity attempts to rebalance in an arbitrarily shorter period than that required in
the NERC BAL-002. In attempting to meet the 60-minute restoration requirement, a Responsible
Entity has two options. First, the BA must carry significantly more Contingency Reserve than is
required to maintain an adequate level of reliability, or second, be prepared to enter an Energy
Emergency Alert 3 and reduce load to restore contingency reserve. By definition, entering an
Energy Emergency Alert indicates reduced reliability. Given normal scheduling practices, a 90minute restoration time allows a Responsibility Entity to restore Contingency Reserve using
normal practices rather than attempting to restore Contingency Reserve in less than 60 minutes
from the initiating event, resulting in an Energy Emergency Alert situation.
4) Standards should not dictate how commercial arrangements are conducted.

Affected Reliability Principles
Reliability Principle 2—The frequency and voltage of interconnected bulk electric systems shall be
controlled within defined limits through the balancing of real and reactive power supply and demand.

Document Information
NA

Reference Uploads
•

Final NWPP RSG SAR for retirement of BAL-002-WECC-2a.docx 410.78 kb

•

History of WECC Reserve 5-7 Spin Merrill Schultz 03032005.docx 15.94 kb

5

Standard Authorization Request
WECC-0142 BAL-002-WECC-2a
Contingency Reserve
Request to Retire
•

Transition from 5-7 to 3-3.docx 13.23 kb

•

WECC Standard BAL-002-WECC-2a—Contingency Reserve.pdf 320.49 kb

Provide additional comments (if needed).
Costs are unnecessarily increased in the interconnection by misallocating resources as Contingency
Reserve that could be used for other operational needs to maintain reliability. By requiring
Contingency Reserve beyond MSSC and in excess of what is necessary to maintain an adequate level of
reliability, additional resources are needed to maintain reliability for other needs, such as variability
and fast ramping. Retirement of BAL-002-WECC-2a will allow a BA to allocate capacity resources to
most efficiently meet the needs of the BA, reducing overall costs.
The NWPP RSG leadership discussed the SAR with the WECC Performance Work Group and
Operating Committee and there was no negative feedback received.
The 24 Balancing Authorities of the NWPP RSG are in full support of this SAR.

6

Black, Shannon
From:
Sent:
Subject:
Attachments:

Black, Shannon
Tuesday, 20 October, 2020 4:52 PM
WSC to Consider Multiple Standard Authorization Requests (SAR)
WECC-0142 Request to Retire BAL-002-WECC-2a - Attachment A - Standard
Authorization Request.pdf; WECC-0143 COM-001-WECC-2.1 SAR Five-year Review.pdf;
WECC-0144 INT-020-WECC-CRT-2.1 SAR Five Year.pdf; WECC-0145 INT-021-WECCCRT-2.2 SAR Five Year.pdf

WSC to Consider Multiple Standard Authorization Requests (SAR)
During the October 22, 2020 meeting of the WECC Standards Committee (WSC), the WSC
will consider four projects for development. The proposed SARs are attached,


WECC-0142 BAL-002-WECC-2a Contingency Reserve – consider for full retirement



WECC-0143 COM-001-WECC-2.1 Digital Circuit Synchronization – five year review



WECC-0144 INT-020-WECC-CRT-2.1 Digital Interchange Schedule – five year review



WECC-0145 INT-021-WECC-CRT-2.2 WECC Interchange Tool – five year review

W. Shannon Black, JD
WECC Consultant, Standards Processes
(503) 307-5782
[email protected]

1

Black, Shannon
From:
Sent:
Subject:

Black, Shannon
Thursday, 5 November, 2020 12:15 PM
WECC-0142, Request to Retire BAL-002-WECC-2a Contingency Reserve - Drafting Team
Solicitation

Drafting Team Solicitation
Drafting Team nominations are being solicited for the following project:


WECC-0142, BAL-002-WECC-2a, Contingency Reserve, Request to Retire

This is a request to retire the Standard in its entirety.
If you have an interest in participating on this drafting team, please submit a “DT
Nomination Form” found on the Standards Under Development page. From the Tracking
Number drop down menu, please select “WECC-0142.”
Nominations will be addressed at the next scheduled WECC Standards Committee (WSC)
meeting, currently targeted for December 2020.
W. Shannon Black, JD
WECC Consultant, Standards Processes
(503) 307-5782
[email protected]

1

Black, Shannon
From:
Sent:
Subject:

Black, Shannon
Wednesday, 28 April, 2021 11:01 AM
WECC-0115 BAL-002-WECC-3, Contingency Reserve - FERC Approved

WECC-0115 BAL-002-WECC-3, Contingency Reserve – FERC Approved
On April 15, 2021, FERC approved WECC-0115 BAL-002-WECC-3, Contingency Reserve,
retiring Requirement R2 of BAL-002-WECC-2a. (Docket No. RM19-20-000) To ensure
reliability is maintained in the absence of R2, an information filing will be required 30
months following implementation.
W. Shannon Black, JD
WECC Consultant, Standards Processes
(503) 307-5782
[email protected]

1

Black, Shannon
From:
Sent:
Subject:

Black, Shannon
Wednesday, 30 March, 2022 1:06 PM
WECC-0142 BAL-002-WECC-3 Notice of Project in Abeyance

WECC-0142 BAL-002-WECC-3 Contingency Reserve - Request to Retire
The WECC-0142 project is in abeyance until further notice. In the interim, the drafting team
will meet off-line to draft a white paper in support of retiring the entire Standard. Once the
team has a work product for review, the team will reconvene for public review to include
standardized comment/response.

W. Shannon Black, JD
WECC Consultant, Standards Processes
(503) 307-5782
[email protected]

1

WECC-0142 BAL-002-WECC-3
Contingency Reserve
Request to Retire
Posting for Comment 1
WECC-0142 Drafting Team
11/15/2024

WECC-0142 BAL-002-WECC-3—Contingency Reserve—Request to Retire
Executive Summary
This document supports and requests full retirement of WECC Regional Reliability Standard (RRS)
BAL-002-WECC-3, Contingency Reserve.
In FERC Order No. 672, when considering approval of RRSs, FERC agreed to accept two kinds of
regional differences: (1) a regional difference that is more stringent than the continent-wide Reliability
Standard, including a regional difference that addresses matters that the continent-wide Reliability
Standard does not; and (2) an RRS that is necessitated by a physical difference in the Bulk-Power
System. 1
Order 672 also provides authority to retire an RRS.
Since the start of BAL-002-WECC-3 and its predecessors (2007), the original standard and each later
iteration have continued as more stringent than the continent-wide equivalent, NERC BAL-002-X,
Disturbance Control Standard. Among other things, WECC’s BAL-002-WECC series has always
required holding more reserves than the continent-wide equivalent. Specifically, BAL-002-WECC-3,
Requirement R1.1.1 requires the applicable entity to hold reserves based on three percent of load and
three percent of generation.
Though Requirement R1.1.1 was approved in BAL-002-WECC-1, that approval was predicated on
distributing burden and the availability of deliverability. 2 There has never been a technical study
proving that holding reserves more than that required under NERC BAL-002-X enhances the reliability
of the Western Interconnection.
By contrast, as variable generation is added to the Interconnection, there is increasing evidence that
holding excess reserves may be inhibiting reliability across the Interconnection. FERC’s recent Order
901 echoes these concerns, addressing operational and performance concerns for variable resources.
Restated, within the Western Interconnection, applicable entities are holding more reserves than the
rest of the continent, even though there is no technical basis for doing so. In FERC Order 693, in which
NERC BAL-002-1 was first approved, at P341, FERC states:
341. We believe a continent-wide contingency reserves policy would assure [sic] that there are
adequate magnitude and frequency responsive contingency reserves in each Balancing
Authority. This will improve performance so that no Balancing Authority will be doing less than
its fair share.” (Emphasis added.)

Order No. 672 at P 331. See also FERC Order 740, P 4 and P 23.
https://www.nerc.com/pa/Stand/Resources/Documents/FERC'S_Criteria_for_Approving_Reliability_Standards_fr
om_Order_672.pdf
2 FERC Order 740, Remand.
1

2

WECC-0142 BAL-002-WECC-3—Contingency Reserve—Request to Retire
By extension, retiring BAL-002-WECC-3 in favor of NERC BAL-002-3, ensures that no Balancing
Authority will be doing more than its fair share.
Further, holding that excess may be inhibiting the use of variable generation by unnecessarily
sequestering generation. As a result, BAL-002-WECC-3 creates a mandated scenario in which reserves
are used inefficiently, artificially withheld from the marketplace, and potentially driving up the cost of
power unreasonably.

3

WECC-0142 BAL-002-WECC-3—Contingency Reserve—Request to Retire

Table of Contents
Introduction .............................................................................................................................................................5
Standard of Review ................................................................................................................................................6
Procedural History..................................................................................................................................................7
Development History (Pre-1996 to 2024) ............................................................................................................8
Structural Overview of BAL-002-WECC-3 ....................................................................................................... 11
Purpose ............................................................................................................................................................... 11
Applicability ...................................................................................................................................................... 11
Requirements ..................................................................................................................................................... 11
Requirement R1 ............................................................................................................................................. 11
Requirement R2 ............................................................................................................................................. 11
Requirement R3 ............................................................................................................................................. 12
Requirement R4 ............................................................................................................................................. 12
Reliability will be Maintained........................................................................................................................... 13
Vital Public Interests will be Enhanced .......................................................................................................... 18
Market Timing Issues ....................................................................................................................................... 18
Capacity Could be Better Utilized than Simply Holding Reserve .............................................................20
Conclusion ............................................................................................................................................................. 22

4

WECC-0142 BAL-002-WECC-3—Contingency Reserve—Request to Retire

Introduction
Per the Standard Authorization Request (SAR) for WECC-0142, 3 this document explores the full
retirement of WECC RRS BAL-002-WECC-3, Contingency Reserve.
The following will show that, if the standard is retired, reliability will continue to be maintained
through NERC BAL-002-3, and may be enhanced as otherwise sequestered resources may more
efficiently backstop variable generation.
By retiring BAL-002-WECC-3 in favor of NERC BAL-002-3:
•

Dispatchable resources can be used to support variable generation, addressing issues raised by
FERC in Order 901.

•

A more efficient use of resources should negate any current negative impacts on the market,
thereby enhancing vital public interests.

As the Procedural and Historic Development sections note, BAL-002-WECC-3 is an evolution of prestandards originating in the 1990s. Never during the estimated 30 years of its existence has there been a
technical justification for the values and procedures required in the standard. Rather, the stated values
and procedures are the result of generalized negotiations taking place between the parties. Because
these values and procedures are negotiated, the content of BAL-002-WECC-3 is the lowest common
denominator and does not meet the requirements of FERC Order 672. 4
Because BAL-002-WECC-2a, Contingency Reserve, Request to Retire Requirement R2 provided the
technical support for retiring Requirement R2, arguments in that filing are not revisited here. 5

See WECC-0142 BAL-002-WECC-3, Contingency Reserve, Request to Retire, home page, at the SAR accordion.
FERC Order 672, P329 and P330.
5 Approved by the NERC Board of Trustees on August 15, 2019, filed with FERC on September 9, 2019.
3
4

5

WECC-0142 BAL-002-WECC-3—Contingency Reserve—Request to Retire

Standard of Review
While the Commission may approve an RRS that is more stringent than a parallel continent-wide
standard, the Commission may also retire such a standard. 6
“While a Regional Entity may propose regional Reliability Standards that address specific,
unique regional conditions and circumstances, such regional Reliability Standards can be retired if
those justifications are no longer relevant. Accordingly, the Commission may approve retirement of
a more stringent regional requirement “if the Regional Entity demonstrates that the continentwide Reliability Standard is sufficient to ensure the reliability of that region.” 7 (Emphasis
added.)
In doing so, the Commission must give due weight to the technical expertise of a Regional Entity, like
WECC, that is organized on an interconnection-wide basis with respect to the regional differences
applicable to the Western Interconnection.
The technical qualifications of the subject matter experts compiling this paper are provided with this
filing, as presented and approved by the WECC Standards Committee (WSC).

The Commission approves regional differences proposed by Regional Entities, such as Regional Reliability
Standards and Variances, if the regional difference is just, reasonable, not unduly discriminatory or preferential,
and in the public interest. 16 U.S.C. § 824o(d)(2) and 18 C.F.R. § 39.5(a). (See also) Additionally, Commission
Order No. 672 requires further criteria for regional differences. A regional difference from a continent-wide
Reliability Standard must either be:
(1) more stringent than the continent-wide Reliability Standard, including a regional difference that addresses
matters that the continent-wide Reliability Standard does not; or is,
(2) necessitated by a physical difference in the Bulk-Power System.
7 Version One Regional Reliability Standard for Resource and Demand Balancing,
Order No. 740, 75 FR 65964 (Oct. 27, 2010), 133 FERC ¶ 61,063, P 30 (2010). See also: FERC, 18 CFR Part 40, Docket
No. RM19-20-000, WECC Regional Reliability Standard BAL-002-WECC-3 (Contingency Reserve), p.5
6

6

WECC-0142 BAL-002-WECC-3—Contingency Reserve—Request to Retire

Procedural History
In 1996, the Western Systems Coordinating Council (WSCC) 8 adopted the WSCC Reliability Criteria,
Minimum Operating Reliability Criteria (MORC). The MORC prescribed levels of reserves that became
BAL-002-WECC-3, effective 2021.
In 1999, the MORC became the WECC Reliability Management System (RMS), a contract-based system
of accountability that pre-dated mandatory standards.
As the industry approached the onset of mandatory standards (2007) and memorialization of legacy
operating practices, the content of the RMS was adapted and approved as BAL-STD-002-0, Operating
Reserves (2007). That standard was an attempt to translate the substantive content of the RMS into the
sought-after NERC/FERC format of today’s reliability standards. The content was accepted “as is” with
its origins in the 1996 MORC; albeit, the early standard was remanded for remediation, largely on
format and structural grounds.
In 2013, FERC accepted remediations to BAL-002-WECC-2.
In 2017, an interpretation was added (BAL-002-WECC-2a), and later incorporated into BAL-002-WECC3, in which Requirement R2 was approved for retirement, with an effective date of August 15, 2019.
In 2024, the Western Interconnection still adheres to the 1996 levels for reserves. This means that, for 28
years, the Western Interconnection has held more reserves than the rest of the continent (NERC BAL002-3) even though there has never been technical justification to do so.

The Western Systems Coordinating Council (WSCC) was formed in 1967 by 40 power systems to coordinate the
planning and operations of the electric system in western North America. The WSCC's goal was to provide
reliable power to the public.

8

7

WECC-0142 BAL-002-WECC-3—Contingency Reserve—Request to Retire

Development History (Before 1996 to 2024)
Before 1996, members of the WSCC voluntarily operated the Western Interconnection according to the
MORC. 9 Although the MORC contained provisions for generation control, generation performance,
and Contingency Reserve, the MORC provided no technical support for the reserve thresholds and
characteristics it set. 10 Rather, the operating thresholds were established by negotiation—not technical
analysis. If this approach were adopted today, FERC would likely deny approval of the standard as
contrary to FERC Order 672, P329. 11
In July and August of 1996, the Western Interconnection experienced two widespread outages resulting
from improper vegetation management. The resultant outage reports 12 13 made several
recommendations that would later be adopted in the 1999 WECC RMS. 14 15 The WECC Operating
Committee’s recommendation produced portions of the RMS that later evolved into WECC Standard
BAL-STD-002-0, Operating Reserves, ultimately becoming BAL-002-WECC-3. Like the other initial

MORC, Maintenance Coordination: 1. Sharing information. The security and reliability of the interconnected
power system depends upon periodic inspection and adequate maintenance of generators, transmission lines and
associated equipment, control equipment, communication equipment, relaying equipment, and other system
facilities. Entities and coordinated groups of entities must establish procedures and responsibility for
disseminating information on scheduled outages and for coordinating scheduled outages of major facilities which
affect the security and reliability of the interconnected power system.
10 Minimum Operating Reliability Criterion, Section 1, Generation Control and Performance
11 FERC Order 672. P329. The proposed Reliability Standard must not simply reflect a compromise in the ERO’s
Reliability Standard development process based on the least effective North American practice—the so‐called
“lowest common denominator”—if such practice does not adequately protect Bulk‐Power System reliability.
Although the Commission will give due weight to the technical expertise of the ERO, we will not hesitate to
remand a proposed Reliability Standard if we are convinced it is not adequate to protect reliability.
12 The outage reports are available upon request. Western Systems Coordinating Council (WSCC) Disturbance
Report for the Power System Outage that Occurred on the Western Interconnection August 10, 1996, as approved
by the WSCC Operations Committee on October 18, 1996
13 “f. The WSCC Operations Committee shall assess whether the levels and allocation of operating reserves
contributed to the severity of this disturbance and implement corrective measures as appropriate.” Western
System Coordinating Council Disturbance Report, For the Power System Outages that Occurred on the Western
Interconnection on 2 JUL 1996. Approved by the WSCC Operations Committee on September 19, 1996. RMS
Outage Report, page 14.
14 The RMS was approved 1 SEP 1999. WECC Comment Report – WECC Tier 1- RMS Standard – (BAL-STD-002-0)
Question 4, Attachment 2, page 9.
15 “The majority of these standards were specifically developed to address and mitigate main causes of the two
major system outages that occurred in the Western Interconnection in July and August of 1996.” Agenda Item 3,
Board of Trustees Meeting, March 12, 2007, page 4
9

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WECC-0142 BAL-002-WECC-3—Contingency Reserve—Request to Retire
standards, the language of the original standard was a translation of the language contained in the
RMS. 16
In March 1997, noting that federal remedial legislation could take years to enact, the WSCC trustees
created the WSCC RMS Policy Group 17 establishing a contract-based operational system known as the
RMS. 18 19 In establishing the RMS, the WSCC RMS Policy Group reviewed all NERC and WECC
reliability criteria, identified specific criteria deemed critical for reliability management, then moved
those criteria into the RMS through a three-phase implementation plan. 20
On April 14, 1999, FERC asserted jurisdiction over the RMS.
Between September 1998 and February 2000 (phase two of the three-phase RMS implementation), the
WSCC turned the content of the RMS into the first mandatory reliability standards (aka Version Zero,
2007). BAL-SDT-002-0, Contingency Reserve was part of that translation.
On December 22, 2006, WECC submitted a request to NERC to approve, and send to FERC for
approval, eight proposed RRSs. WECC referred to the eight proposed standards as its Tier One

WECC states that the proposed regional Reliability Standards, which are exact translations of existing regional
criteria, either address matters not addressed in the Commission-approved ERO Reliability Standards or contain
more stringent requirements than the ERO standards. (FERC accepted Tier One standards evolving from the
RMS. AKA: Tier One Order.) FERC, 119 FERC ¶ 61,260 United States of America, Federal Energy Regulatory
Commission, Order Approving Regional Reliability Standards for the Western Interconnection and Directing
Modifications (Issued June 8, 2007), page 19.

16

Following the enactment of EPAct 2005 and the establishment of mandatory Reliability Standards applicable to
all owners, operators, and users of the BPS, WECC sought to translate certain of its existing practices under its
RMS reliability criteria into regional Reliability Standards to supplement the continent-wide Reliability Standards
the Commission approved in Order No. 693. To that end, WECC established a task force to identify criteria in the
RMS that should be binding on all BPS users, owners, and operators in the Western Interconnection, not just the
Transmission Operators subject to the RMS. The task force chose eight of the identified criteria, which had the
highest priority and could be implemented in the near term for translation into regional Reliability Standards.
United States of America Before the Federal Energy Regulatory Commission, North American Electric Reliability
Corporation (NERC), Docket No. RM16-10-000, Supplemental Information for Petition of the NERC and WECC
for Approval of retirement of Regional reliability Standard TOP-007-WECC-1a, page 5.

17

18

Hearing

Electric Reliability Corporation, Helping Owners, Operators, and Users of the Bulk Power System Assure
Reliability and Security for More Than 50 Years, By David Nevius, Senior Vice President 1979–2012, Page 40-41.

19

20

Hearing

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WECC-0142 BAL-002-WECC-3—Contingency Reserve—Request to Retire
standards originating from the RMS because the proposed standards were translations of standards
that were already mandatory within the Western Interconnection as part of the RMS. 21
Those eight standards—that included Tier One WECC-BAL-STD-002-0 (Operating Reserves) - were
near-exact translations of existing WECC criteria that FERC earlier accepted as part of the WECC RMS
program. 22 Because the content was a near-exact translation, the format did not match that required by
NERC/FERC. This would later lead to a remand of BAL-002-WECC-1 to ensure conformity.
On January 9, 2007, NERC provided WECC with a report of its preliminary findings about the request
from December 22, 2006, and provided WECC with a list of required remediations. 23 The request
largely addressed styles, formats, and corrections to compliance sections. The NERC Board of Trustees
approved the Tier One request subject to remediation and sent the eight proposed standards to FERC
with a request for approval.
In June 2007, FERC approved WECC’s submittal of eight reliability-crucial Tier One standards thereby
transitioning from the RMS system to that of FERC-approved NERC Reliability Standards. 24 Although
earlier versions lacked technical support, FERC agreed with
“WECC, WIRAB [Western Interconnection Regional Advisory Board] and NERC that
approval of [WECC’s early BAL] under section 215 would enhance reliability in the
Western Interconnection by making WECC’s current practices binding on all relevant
entities in the region and by strengthening WECC’s compliance and enforcement
authority.” 25

North American Electric Reliability Corporation, Docket No. RR07-___-000, III. BACKGROUND ON THE
DEVELOPMENT OF THE WECC REGIONAL RELIABILITY STANDARDS, Debra A. Palmer of Schiff/Hardin
(1666 K STREET N.W., SUITE 300, WASHINGTON, DC 20006) on March 26, 2007.
22 Loc. Cit. IV. Overview of the Proposed WECC Regional Reliability Standards, page 6.
23 NERC DECISION APPROVING, WITH CONDITIONS, RELIABILITY STANDARDS PROPOSED BY
WESTERN ELECTRICITY COORDINATING COUNCIL, page 2. (Approved by Board of Trustees March 12,
2007)
24FERC Order Approving Regional Reliability Standards for the Western Interconnection and Directing
Modifications, Docket No. RR07-11-000, (Issued June 8, 2007)
25 Tier One Order, p. 43. See also, “The proposed regional Reliability Standards would make eight of those RMS
criteria binding on the applicable subset of users, owners and operators of the Bulk-Power System in the United
States portion of the Western Interconnection, as identified in each proposed standard. The regional Reliability
Standards would supplement rather than replace the Commission-approved Reliability Standards developed by
the ERO that will take effect in June 2007. Tier One, p. 10.
21

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WECC-0142 BAL-002-WECC-3—Contingency Reserve—Request to Retire

Structural Overview of BAL-002-WECC-3
Purpose
The Purpose of currently effective RRS BAL-002-WECC-3—Contingency Reserve is to provide an RRS
specifying “the quantity and types of Contingency Reserve required to ensure reliability under normal
and abnormal conditions.” 26
The NERC Glossary defines Contingency Reserve as:
“The provision of capacity that may be deployed by the Balancing Authority to respond to a Balancing
Contingency Event and other contingency requirements (such as Energy Emergency Alerts as specified
in the associated EOP standard). A Balancing Authority may include in its restoration of Contingency
Reserve readiness to reduce Firm Demand and include it if, and only if, the Balancing Authority:
•

is experiencing a Reliability Coordinator declared Energy Emergency Alert level, and is
utilizing its Contingency Reserve to mitigate an operating emergency in accordance with its
emergency Operating Plan.

•

is utilizing its Contingency Reserve to mitigate an operating emergency in accordance with its
emergency Operating Plan.”

Applicability
BAL-002-WECC-3 applies to Balancing Authorities (BA), unless the BA is a member of a Reserve
Sharing Group (RSG), in which case the RSG becomes the applicable entity.

Requirements
The standard consists of four requirements.
Requirement R1
•

Provides that each BA and RSG must maintain a minimum amount of Contingency Reserve,
except within the first sixty minutes following an event requiring the activation of Contingency
Reserves, and that the Contingency Reserve must consist of any combination of a list of
specified reserve types.

Requirement R2
•

26

Reserved. Retired, subject to cyclical field tests.

BAL-002-WECC-3, Contingency Reserve, Purpose.

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WECC-0142 BAL-002-WECC-3—Contingency Reserve—Request to Retire
Requirement R3
•

Each Sink BA and RSG must maintain an amount of Operating Reserve, in addition to the
minimum Contingency Reserve in Requirement R1, equal to the amount of Operating Reserve–
Supplemental for any Interchange Transaction designated as part of the Source Balancing
Authority’s Operating Reserve–Supplemental or source Reserve Sharing Group’s Operating
Reserve–Supplemental, except within the first sixty minutes following an event requiring the
activation of Contingency Reserve.

Requirement R4
•

Each Source BA and RSG must maintain an amount of Operating Reserve, in addition to the
minimum Contingency Reserve amounts identified in Requirement R1, equal to the amount
and type of Operating Reserves for any Operating Reserve transactions for which it is the
Source BA or RSG.

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WECC-0142 BAL-002-WECC-3—Contingency Reserve—Request to Retire

Reliability will be Maintained
Upon retirement of BAL-002-WECC-3, reliability will be maintained by NERC BAL-002-3, Disturbance
Control Standard—Contingency Reserve for Recovery from a Balancing Contingency Event, reinforced
by the enhanced availability of resources currently unavailable under BAL-002-WECC-3.
Replacing BAL-002-WECC-3 with NERC BAL-002-3 Mitigates Reliability Gaps associated
with Variable Generation
As highlighted by FERC in its Order 901, with the growing amount of variable generation replacing
more responsive and dispatchable resources, the industry faces the dilemma of how to support these
new resources. 27 Unlike traditional resources, much of the new variable generation cannot be quickly
dispatched, thus creating a gap in reliability. FERC acknowledged that gap, noting that neither
business-as usual nor existing reliability standards will remedy this concern. Finally, FERC also
recognizes the value that steps taken must apply on a continent-wide basis. 28
Replacing BAL-002-WECC-3 with the continent-wide NERC BAL-002-3 takes immediate steps towards
meeting FERC’s concerns.
In Order 901, FERC states:
“[W]e continue to find that as the resource mix trends towards higher penetrations of IBRs, the
need to reliably integrate these resources into the Bulk-Power System is expected to grow, and
that the currently effective Reliability Standards do not adequately address IBR reliability risks.
The continuing risks that the increasing penetration of IBRs pose to the reliable operation of the BulkPower System underscore the need for mandatory Reliability Standards to address these issues on a
nationwide basis.” (Emphasis added.) Order 901, P24.
When BAL-002-WECC-3 is retired and replaced with NERC BAL-002-3, the amount and type of
reserves required to be held back within the Western Interconnection will decrease. That frees those
resources to be plied against load. Within the Western Interconnection, a vast majority of these
sequestered resources are immediately dispatchable (such as hydro), thus serving as the perfect
resource to match the less predictable response of variable generation.

FERC Order 901, P11-15, 185 FERC ¶ 61,042, United States of America, Federal Energy Regulatory Commission
(FERC), 18 CFR Part 40, Docket No. RM22-12-000; Reliability Standards to Address Inverter-Based Resources,
October 19, 2023. Hereafter: Order 901
28 Order 901, P24.
27

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WECC-0142 BAL-002-WECC-3—Contingency Reserve—Request to Retire
By making these dispatchable resources more operationally available, the secondary benefits may be to
bolster the supply of generation to the market with the unintended favorable consequence of driving
down the cost of power. This potential secondary benefit directly addresses vital public interests. 29
Dispatchable Resources Contribute Significantly to Essential Reliability Services (ERS) 30
ERSs consist of frequency control, ramping capability, and voltage control.
Frequency control is necessary because the electric grid is designed to operate at a frequency of 60 hertz
(Hz). Deviations from 60 Hz can have destructive effects on generators, motors, and equipment of all
sizes and types. It is critical to maintain and restore frequency after a disturbance such as the loss of
generation. This requires an instantaneous (inertial) response from some resources and a fast response
from other resources to slow the rate of fall during the arresting period, a fast increase in power output
during the rebound period to stabilize the frequency, and a more prolonged contribution of additional
power to compensate for lost resources and bring system frequency back to the normal level. Two
NERC Reliability Standards address this:
•

BAL-002-3 Disturbance Control Standard—Contingency Reserve from a Balancing Contingency
Event

•

BAL-003-2 Frequency Response and Frequency Bias Setting

Adequate ramping capability (the ability to match load and generation at all times) is necessary to
maintain system frequency. Changes to the generation mix or the system operator’s ability to adjust
resource output can impact the ability of the operator to keep the system in balance. NERC Reliability
Standard BAL-001-2 (Real Power Balancing Control Performance) addresses this issue.
Voltage must be controlled to protect system reliability and move power where it is needed in both
normal operations and following a disturbance. Voltage issues tend to be local in nature, such as in
sub-areas of the transmission and distribution systems. Reactive power is needed to keep electricity
flowing and maintain necessary voltage levels. Several NERC Reliability Standards address voltage
control.
Restated, replacing BAL-002-WECC-3 with NERC BAL-002-3 frees dispatchable resources to address
FERC-identified reliability gaps created by variable generation, and may bolster vital public interests

“335. Finally, we understand that at times development of a proposed Reliability Standard may require that a
particular reliability goal must be balanced against other vital public interests, such as environmental, social, and
other goals. We expect the ERO to explain any such balancing in its application for approval of a proposed
Reliability Standard. “ (Emphasis added.) Order 693, P35.
30 “Essential Reliability Services (ERS) are the elemental ‘reliability building blocks’ from resources (generation
and demand) necessary to maintain Bulk Power System (BPS) reliability.” NERC ERS Task Force – Scope – 2014.
29

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WECC-0142 BAL-002-WECC-3—Contingency Reserve—Request to Retire
by driving down the cost of power. Because adequate levels of reserves are established in NERC BAL002-3, and supported by BAL-003-2, BAL-002-WECC-3, Requirements R1 through R4 are not needed.
Replacing BAL-002-WECC-3 With NERC BAL-002-3 Provides Sufficient Reserves at a
Continent-Wide Level
In the earliest stages of the Western Interconnection’s strides to establish adequate Contingency
Reserves, the applicable entity’s reserves were established by BAL-STD-002-0, Operating Reserves, at
5% of hydro generation and 7% thermal generation (50% spinning and 50% non-spinning). 31 These
thresholds were not technically supported; they were the result of contractual negotiations. Today,
such a standard would likely not be approved by FERC as violative of the principles established in
FERC Order 672. (See foot note 2.)
As BAL-STD-0-2 was replaced with later iterations of that standard, the result was today’s BAL-002WECC-3, in which the Responsible Entity’s reserves are set at:
R1.1.1 “The greater of either:
•

The amount of Contingency Reserve equal to the loss of the most severe single contingency; 32
(or)

•

The amount of Contingency Reserve equal to the sum of three percent of hourly integrated
Load plus three percent of hourly integrated generation.”

Bullet one of BAL-002-WECC-3 describes the Most Severe Single Contingency, or MSSC.
The MSSC ensures that all entities can recover Area Control Error within 15 minutes. The MSSC serves
as the upper Contingency Reserve threshold for all interconnections, except the Western
Interconnection. Within the Western Interconnection, the levels of reserve set by BAL-002-WECC-3 can
exceed that of the rest of the continent that is protected by FERC-approved BAL-002-3. As a result, the
Western Interconnection carries an excess of reserve that exacerbates concerns raised by FERC in Order
901 wherein FERC addresses the need for continent-wide standards to backstop the operational
performance of variable generation. Comparing NERC BAL-002-3 with BAL-002-WECC-3 illustrates
this outcome.
NERC BAL-002-3 states that the BA and the RSG are not subject to compliance with BAL-002-3, R1 for
multiple events that exceed the MSSC. NERC BAL-002-3 requires the applicable entity to deploy
Contingency Reserve up to its MSSC; however, it does not require Contingency Reserve deployment
beyond MSSC.

See Attachment - Transition from 5-7 to 3-3, as described in 2005 by Merrill Schultz; see also Attachment History of WECC Reserve 5-7 Spin Merrill Schultz, March 3, 2005; see also BAL-STD-002-0, Operating Reserves.
32 Also known as the Most Severe Single Contingency (MSSC).
31

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WECC-0142 BAL-002-WECC-3—Contingency Reserve—Request to Retire
By contrast, BAL-002-WECC-3 requires the applicable entity to maintain a level of Contingency
Reserves exceeding that required under NERC BAL-002-3, as approved by FERC. Specifically, BAL-002WECC-3, Requirement R1 requires the applicable entity to carry reserves that equal or exceed the
entity’s MSSC—beyond that required by BAL-002-3 that adequately serves the balance of the continent.
Among other things, this means these valuable dispatchable resources in excess of the MSSC cannot be
used to meet FERC’s goal of backstopping variable resources as identified in FERC Order 901.
While application of BAL-002-3 could free resources to enhance reliability, application of BAL-002WECC-3 can inhibit reliability when resources are withheld that could otherwise serve load and
backstop variable resources.
For example:
Using historical data from January 2020 - May 2024, comparison of the hourly Contingency Reserve
Requirement (calculated using 3% generation and 3% load) to the Most Severe Single Contingency
(MSSC), the results identified there was more than 5,000 MW of capacity available during the
summertime peak hours and between 2,000-2,500 MW during the remaining hours of the year. See
figure below.

Figure 1: Reserves in excess of MSSC

The Shortened Execution Time of BAL-003-WECC-3 Inhibits Reliability Due to Market
Rules in the Western Interconnection
BAL-002-WECC-3, Requirements R3 and R4 require the applicable entity to restore Contingency
Reserve within 60 minutes of the initiating event. By contrast, BAL-002-3 requires the applicable entity
to achieve the same task in 105 minutes. As a result, BAL-002-WECC-3 requires the performance of the
same task 45 minutes earlier than its continent-wide counterpart. This shortened period inhibits
reliability in that it forces the applicable entities into transactions agreed upon during an arbitrarily
shortened time window. Like BAL-002-3, Requirement R1., there is no technical support suggesting

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WECC-0142 BAL-002-WECC-3—Contingency Reserve—Request to Retire
that rushing this transaction enhances reliability—yet it remains in force 28 years after its inception,
still lacking any technical support.
Further, the restoration of reserves in a 60-minute timeframe is restrictive on the entity’s ability to
secure additional resources within the established business practices in the region. The NERC Standard
of up to 105 minutes (90 minutes after the 15 minutes Contingency Recovery Period) after the event has
less commercial impact and is acceptable from both a commercial standpoint as well as an operational
standpoint.
The WECC requirement of 60 minutes from start of a DCS event restricts the deficient entity from
rescheduling resources to replace those that were lost during the event. Western market practices
require schedules to be submitted and approved well in advance to ensure reliability, and once the
schedule windows close, it is difficult to make last minute changes. Before markets, when transactions
were bilateral, a recovery of generation resources was more flexible, and could be more quickly
executed.
The NERC BAL-002-3 Contingency Reserve Restoration Period of up to 105 minutes allows applicable
entities to use normal market scheduling practices to replace lost generation. FERC’s approval of NERC
BAL-002-3 shows its belief that the NERC standard of 105 minutes (90 plus 15) is adequate and does
not degrade reliability.
In attempting to meet the 60-minute restoration requirement, the applicable entity has two options.
First, the BA must carry significantly more Contingency Reserve than is required to maintain an
adequate level of reliability, or second, be prepared to enter an Energy Emergency Alert 3 which allows
the BA to deploy Contingency Reserve, and to serve load. By definition, entering into an Energy
Emergency Alert is an indication of reduced reliability. Given normal scheduling practices, a 90-minute
restoration time allows a Responsible Entity to restore Contingency Reserve using normal established
market scheduling practices.
In addition, many entities own BES equipment in more than one interconnection. Having a single
standard enhances these entities’ ability to stay in compliance with the standard using consistent
business practices across the interconnections.
Reserve Thresholds do Not Reflect Resource Mix
Due to the changing resource mix and the proliferation of renewable generation, battery storage, and
retirements of conventional synchronous generation, resource adequacy has become a serious concern.
The BAL-002-WECC standard unnecessarily ties up significant generation which is dispatchable,
frequency responsive and fast ramping. Generation that could be used to meet ramps, follow variable
resources, or simply meet expected loads, is committed to contingency reserve capacity that is not
available to serve load. For example, Western Power Pool’s Northwest Power Pool Reserve Sharing
Group Northwest-Montana zone typically has a 1,200 MW MSSC, yet routinely has over 3000 MWs of
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WECC-0142 BAL-002-WECC-3—Contingency Reserve—Request to Retire
reserves being held under the 3/3 requirement. That available capacity, usually in excess 1800 MW,
could be used to meet other reliability related services obligations. The existing 3/3 contingency reserve
requirement results in the construction of at least 1800 MW of excess generation in the NorthwestMontana zone. The ability to use this generation capacity exceeding the MSSC will also allow entities to
efficiently operate their facilities. Idled excess capacity will be reduced and productive generation
increased.
Under NERC standard NERC BAL-002-3, the Eastern, Texas and Quebec Interconnections operate
without the additional reserve requirement (3% load and 3% generation), and they are allowed to
restore their reserves within 90 minutes. The changing market structure in the Western Interconnection
has made it difficult to fully restore the required reserves within 60 minutes due to market scheduling
timelines. This can lead to implementation of emergency procedures, typically Energy Emergency Alert
3 conditions, due to an energy shortfall precipitated by the 60-minute recovery period. When the
Western markets were mostly bilateral, the 60-minute recovery was consistent with energy scheduling
protocols. Market integration has altered energy scheduling protocols making it very difficult to
modify schedules within 60 minutes of a generation contingency. For these reasons BAL-002-WECC-3
has become obsolete and onerous to western ratepayers, while not enhancing reliability.
Reserves are unused or unloaded generation that are in a state of readiness in case there is sudden loss
of loaded generation. When reserves are held above the MSSC, as they are in the Western
Interconnection, excess capacity must be built that has no other reliability benefit. Every energy
customer absorbs this excess cost. Retirement of BAL-003-WECC-3 reallocates these excess resources to
the benefit of the interconnection in the form of dispatchable, responsive, and available resources to
reliably integrate future variable resources, such as wind, solar, and other renewable resources.

Vital Public Interests will be Enhanced 33 34
Market Timing Issues
The emergence of organized markets in WECC, since the inception of BAL-002-WECC-1 has brought a
new dynamic in the timing and means by which the reserves are procured. The number of participants
in the California ISO Energy Imbalance Market (AKA: Western Energy Imbalance Market, or WEIM)
has grown significantly in the past several years. CAISO EIM market rules require a participating BA to

“Finally, we understand that at times development of a proposed Reliability Standard may require that a
particular reliability goal must be balanced against other vital public interests, such as environmental, social, and
other goals. We expect the ERO to explain any such balancing in its application for approval of a proposed
Reliability Standard.” FERC Order No. 672 at P 335.
34 “The proposed Reliability Standard does not necessarily have to reflect the optimal method, or “best practice,”
for achieving its reliability goal without regard to implementation cost or historical regional infrastructure design.
It should however achieve its reliability goal effectively and efficiently.” FERC Order No. 672 at P 328.
33

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WECC-0142 BAL-002-WECC-3—Contingency Reserve—Request to Retire
balance its resources and loads 75 minutes before the next operating hour (T-75). Failure to do this can
result in financial penalties to the participating BA. This rule has had the effect of discouraging any
bilateral energy trading after T-75 and does not align well with a 60-minute reserve recovery time limit.
No bilateral trading for replacement energy reserve is possible for the next operational hour because
participating WEIM BAs cannot participate in trades within T-75.
This leaves the contingent BA in a resource short position when the 60-minute contingency restoration
time expires. At this point, the contingent BA must activate emergency operating procedures up to
asking the Reliability Coordinator to declare an EEA3, including load shedding to balance the
contingent BA. By extending the contingency restoration time to 105 minutes (15-minute recovery plus
90-minute restoration), the contingent BA has at least 30 minutes to arrange replacement energy in a
bilateral manner from other BAs or schedule their own resource in the WEIM. The additional
contingency reserve recovery time allows the contingent BA to make orderly and planned adjustments
and continue to serve firm load without the implementation of emergency operating procedures, up to
and including shedding firm load.
FERC and the industry have determined that 90 minutes from the end of the recovery period (up to 15
minutes) is sufficient to maintain an adequate level of reliability. The shorter restoration period in the
WECC creates artificial reliability issues as the applicable entity tries to rebalance supply and demand
in an arbitrarily shorter period than that required in the NERC BAL-002-3.
To give a clear understanding of the impact of either option, the following example is provided.
Assume the NWPP RSG’s MSSC is approximately 1,200 MW. Under BAL-002-WECC-3, the NWPP RSG
would normally carry approximately 2,200-4,000 MW of Contingency Reserves depending on the time
of year. Assuming the MSSC occurs, the NWPP RSG would activate 1,200 MW of its reserves and
restore the Area Control Error (ACE) to the pre-event level. Members now have approximately 60
minutes to restore 1,200 MW of reserves while still carrying more than 1,000–2,800 MW, which is
greater than the MSSC, assuming it was not reduced with the loss of the 1,180 MW event. See figure
below.

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WECC-0142 BAL-002-WECC-3—Contingency Reserve—Request to Retire

Figure 2: Reserves in excess of MSSC; January 1, 2020 through May 1, 2024

As discussed earlier, due to market rules related to the WEIM in which most entities are taking part,
new resources cannot be added to an entity’s reserves for the next hour (minimum time to add a
resource under the WEIM (75 minutes), or other emerging markets. If a resource is not already in the
WEIM, it cannot count toward the reserves needed. So, an entity must have already been carrying
reserves greater than required under the WECC standard, or it must reduce load to balance its
resources and loads including reserves. (It can be argued that by reducing loads, you are putting the
interconnection at greater risk because you have removed one available resource, the load, from being
an option for the next event.) To avoid the declaration of an EEA, the NWPP would need to carry an
additional 1,000 MWs above the required reserves or declare an EEA any time the reserves need
restored within 60 minutes of the event.
When entities withhold extra reserves to avoid the EEA, this paradigm keeps 2,500 to 4,000 MWs from
serving load due to the WECC current standard, which has no technical merit, as compared to the
NERC Standard. These additional resources could be used to help integrate more inverter-based
resources or serve loads more economically if it were available for load service rather than being held
out for the third or fourth contingency.
Entering an Energy Emergency Alert indicates reduced reliability. Given normal scheduling practices,
which require bilateral schedules to be completed and approved 75 minutes before the hour, a 60minute restoration time does not allow adequate time for a Responsible Entity to restore Contingency
Reserve in less than 60 minutes from the initiating event, potentially resulting in an Energy Emergency
Alert situation.

Capacity Could be Better Used than Simply Holding Reserve
FERC and the industry have determined that the amount of Contingency Reserve needed to maintain
an adequate level of reliability is the amount of Contingency Reserve needed to replace the MSSC
resource. Holding Contingency Reserve more than MSSC precludes using operating reserve for other

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WECC-0142 BAL-002-WECC-3—Contingency Reserve—Request to Retire
purposes, particularly load and resource balancing in real-time. As the grid transitions from
conventional synchronous generation to more variable renewable resources, increasing capacity will be
needed to manage the variability and faster ramping requirement of these resources. Allocating
reserves in excess of that needed to maintain an adequate level of reliability, or MSSC, ultimately
detracts from reliability.

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WECC-0142 BAL-002-WECC-3—Contingency Reserve—Request to Retire

Conclusion
Retirement of BAL-002-WECC-3 Contingency Reserve would reduce required reserves in WECC
without diminishing the ability to meet the deployment requirement. Freeing up reserves from the
Contingency Reserve requirement would increase the resources available to manage variable resources
and accommodate increased renewable resource integration.
The existing BAL-002-WECC-3 Contingency Reserve sets a BA’s or RSG’s Contingency Reserve
requirement to the greater of the MSSC or 3% of the applicable entity’s generation and 3% of its load.
This 3/3 requirement exceeds MSSC for most responsible entities.
By contrast, NERC Standard BAL-002-3 Disturbance Control Standard—Contingency Reserve for
Recovery from a Balancing Contingency Event, Requirement R1.3.2 states that the BA/RSG is not
subject to compliance with Requirement R1 for multiple events that exceed the MSSC. NERC BAL-0023 requires the applicable entity to deploy Contingency Reserve up to the MSSC but does not require
Contingency Reserve deployment beyond the MSSC.
In BAL-002-3, FERC and the industry have determined that the amount of Contingency Reserve
needed to maintain an adequate level of reliability is the amount of Contingency Reserve needed to
replace the MSSC resource.
Holding Contingency Reserve more than MSSC precludes using operating reserve for other purposes,
particularly load and resource balancing in real-time. As the grid transitions from conventional
synchronous generation to more variable renewable resources, increasing capacity will be needed to
manage the variability and faster ramping requirement of these resources. Allocating reserve in excess
of that needed to maintain an adequate level of reliability, or MSSC, ultimately detracts from reliability.
BAL-002-WECC-3 requires an applicable entity to restore Contingency Reserve within 60 minutes of
the initiating event (as opposed to up to 105 minutes in BAL-002-3), or 45 minutes sooner than required
by BAL-002-3. With respect to impacts to the time to restore Contingency Reserve, FERC and the
industry have determined that 90 minutes from the end of the recovery period (up to 15 minutes) is
sufficient to maintain an adequate level of reliability. By contrast, the 60-minute requirement within
BAL-002-WECC-3 creates potential reliability issues as an applicable entity tries to rebalance in an
arbitrarily shorter period than that required in the NERC BAL-002-3. In attempting to meet the 60minute restoration requirement, an applicable entity has two options. First, the BA must carry
significantly more Contingency Reserve than is required to maintain an adequate level of reliability, or
second, be prepared to enter an Emergency Alert 3 and deploy Contingency Reserve to serve load.
Given normal scheduling practices, a 90-minute restoration time allows an applicable entity to restore
Contingency Reserve without employing emergency procedures.
Retirement of BAL-002-WECC-3 will enhance the reliable operation of the Western Interconnection by
allowing resources that are presently used for overprotecting above the MSSC to be available to meet
22

WECC-0142 BAL-002-WECC-3—Contingency Reserve—Request to Retire
the immediate balancing needs of the Interconnection. This will free those resources to be used as
needed in a rapidly changing system to maintain overall reliability.

23

Do you agree with the Drafting Team's request for the Standard to be retired? Yes/No with a narrative
explanation
Name

Organization

Comment

Kevin Conway

Western Power Pool
PUD No. 1 of Chelan
County

Yes, the Western Power Pool supports the retirement of BAL-002-WECC-3
Yes, CHPD concurs with the Drafting Team’s request to retire the BAL-002-WECC Standard. We support the
rationale outlined in the WECC-0142 Attachment A SAR and the WECC-0142 BAL-002-WECC-3 White Paper.

Adrian Andreoiu
Lindsay Wickizer

BC Hydro
PacifiCorp

Holly Mitchell

Northwestern Energy

Jennie Wike`

Tacoma Power

Michael Jang

Seattle City Light

ChaRee DiFabio

Western Power Pool

Yes
Yes
Yes. The retirement of this standard is long overdue. This retirement will enable WECC to be in line with the
continent-wide NERC BAL-002-3 as the industry rapidly evolves to integrate IBRs and other alternative energy
sources. The retirement will also enhance reliable operations by removing unnecessarily restrictive practices.
Yes
Yes, SCL is in agreement and full support with the Drafting Team's request for the Standard to be retired. The
retirement of the WECC specific Reliability Standard does not diminish or lessen the ability, intent and actions
that are taken during events the standard was initially created to address.
Yes. In review of the NWPP RSG Data, the group holds excess contingency reserve, at least two to three times
the MSSC, that its Participants could utilize to maintain other operational needs, such as supporting the
variable resources and frequency response. In addition, as already noted, it has economic impacts to these
participants since there are associated costs for holding back the Contingency Reserve that could be used
elsewhere to maintain reliability. Last, the timing requirement from 60 minutes to 90 minutes does allow a
more practical restoration period to recover from the event and restore contingency reserve, which should
decrease the numbers and level of a potential EEA3 since the entity will have time to assess more rational

Anna Lavik
Marie Anderson

Puget Sound Energy
GCPUD

Rebecca Zahler

Alan Wahlstrom

Yes, PSE agrees that retirement would improve reliability and free up available generation.
Yes
Yes, the western interconnect is held at a higher standard than the other Interconnects, It is unfair and places an
Southwest Power Pool
additional burden on operating resources as compared to the other Interconnects.

Dwanique Spiller

NV Energy

Steven Ashbaker

Western Electricity
Coordinating Council

1. Yes, NV Energy agrees with the Drafting Team’s request and that it provides operational efficiency,
maintains reliability, simplifies compliance, facilitates better integration of IBRs, and provides economic
Yes, I agree with the Drafting Teams request for the Standard to be retired. Retirement of this standard would
free up excess reserves being held above the MSSC requirements to serve system demand, without reducing
reliability in the WI. This additional available capacity would be better used to address the issues associated
with IBR integration and variable generation.

SMUD, BANC

Yes. SMUD and BANC agree with the Drafting Team that holding Contingency Reserves at a level of 3% load
plus 3% generation is not technically supported and is more than what is needed for bulk power system
reliability. We recognize that BAL-002-WECC-3 may provide additional reliability for the large system events,
such as double Palo Verde unit tripping or Northwest RAS generation tripping, which has occurred in the past.
The Drafting Team should consider adding some analysis in the white paper showing that the reliability risks
associated with these big system events could still be adequately addressed with the retirement of BAL-002WECC-3. In addition, BAL-002-WECC-3 Requirement R3 requires each sink BA and each sink RSG to carry
additional Contingency Reserves for non-firm purchases of Contingency Reserves, and BAL-002-WECC-3
Requirement R4 requires each source BA and each sink RSG to carry additional Contingency Reserves for firm
sales of Contingency Reserves. We recommend that the Drafting Team add some rationale in the white paper
for the retirement of these two requirements.

Cain Braveheart

Bonneville Power
Administration

Yes. Bonneville Power Administration (BPA) believes the current standard requires WECC entities to hold
more contingency reserves than is necessary and allows only 60 minutes to fully recover from an event. With
the number of variable generation resources coming online, the capacity being unused by holding too much for
contingency reserve can be better allocated to ensure reliability of the interconnection and to help balance the
variable energy resources. BPA believes the timing required by the markets causes issues when trying to
replenish reserves in the 60 minutes allocated. The 105 minutes allotted in BAL-002-3 (90 minutes after the
Contingency Event Recovery Period) is better suited for operations in a market environment.

Diana Torres

Imperial Irrigation
District

Yes, As IID is a participant in the NWPP Reserve Sharing Group, those Contingency Reserves must always be
met and held for use. As part of the RSG our reliability will not be compromised. Communication between the
RSG and the BA have remained strong and will correspond and respect the BAL-002-3 NERC standard that
will take the place of BAL-002-WECC-3 standard.

SRP

Yes, SRP does agree with the Drafting Team's request for BAL-002-WECC-3 to be retired. NERC BAL-002-3 has
a proven history of meeting the needs of each interconnection. The requirements in BAL-002-WECC-3 have not
been found to be necessary in their history in the Western Interconnection. With more variable resources in the
interconnection it makes sense to maximize the use of freed up capacity, with the retirement of BAL-002WECC-3, to be used for regulation and capacity needs.

Tim Kelley

Mike Pfeister

Ben Hammer

Yes, Western Area Power Administration (WAPA) enthusiastically supports the retirement of the BAL-002WECC-3 standard. WAPA operates three Balancing Authorities (WALC, WACM, & WAUW) in the WECC
Western Area Power footprint. Each of our BAs also participate in the Northwest Power Pool reserve sharing group. This
Administration - Rocky participation has allowed us to reduce our Contingency Reserve obligation while maintaining reliability. All
three BAs also participate in organized imbalance markets. Operating our BAs and meeting all the NERC
Mountain Region
(NCR05464), Western reliability standards efficiently and economically has become increasingly more difficult over the last few
years. We have a finite amount of capacity on our federal hydro resources to balance our loads and resources,
Area Power
Administration -Desert maintain reliability, and satisfy our statutory delivery obligations. This constraint has been negatively
impacted by the prolonged drought in the West and the increase of Solar and Wind resources that have
Southwest Region
(NCR05461), Western interconnected to our systems. By retiring the more stringent WECC standard, WAPA would realize a
significant reduction to the amount of capacity we would have to commit for Contingency Reserves and would
Area Power
Administration – Upper free up this capacity to manage the variability of existing and future variable renewable
resources.Additionally, WAPA supports extending the time requirement for restoring Contingency Reserves
Great Plains Region
after an event from 60 minutes to 105 minutes. This approach makes more operational and commercial sense.
(NCR05467)
Western market practices have made the restoration of Contingency Reserves more challenging and introduced
more economic and operational risks.WAPA is concerned with maintaining a standard that is not proven, not

Pablo Oñate

El Paso Electric

Robert Follini

Avista Corporation

Brooke Jockin

Portland General
Electric (PGE)

Yes. Historical background and technical rationale prompt merit for standard retirement.
YES. The request to retire BAL-002-WECC-3 is justified and needed for the Western Interconnection. The
simple facts clearly articulated in the White Paper that system reliability is not impacted negatively by this
change, and is likely enhanced, while ensuring better use of existing generating resources, both variable and
base, should be clear enough justification to retire BAL-002-WECC-3.
Yes.

<Limited-Disclosure>

WECC-0142 BAL-002-WECC-3
Contingency Reserve
Request to Retire
WECC-0142 Drafting Team
01/21/2025

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WECC-0142 BAL-002-WECC-3—Contingency Reserve—Request to Retire
Executive Summary
This document supports and requests full retirement of WECC Regional Reliability Standard (RRS)
BAL-002-WECC-3, Contingency Reserve.
In FERC Order No. 672, when considering approval of RRSs, FERC agreed to accept two kinds of
regional differences: (1) a regional difference that is more stringent than the continent-wide Reliability
Standard, including a regional difference that addresses matters that the continent-wide Reliability
Standard does not; and (2) an RRS that is necessitated by a physical difference in the Bulk-Power
System. 1
Order 672 also provides authority to retire an RRS.
Since the start of BAL-002-WECC-3 and its predecessors (2007), the original standard and each
subsequent iteration have continued as more stringent than the continent-wide equivalent, NERC BAL002-X, Disturbance Control Standard. Among other things, WECC’s BAL-002-WECC has always
required most WECC entities to hold more reserves than the continent-wide equivalent. Specifically,
BAL-002-WECC-3, Requirement R1.1.1 requires the applicable entity to hold the greater of, either the
amount of Contingency Reserve equal to the loss of the most severe single contingency or the amount
of Contingency Reserve equal to the sum of 3% of hourly integrated load and 3% of hourly integrated
generation.
Though Requirement R1.1.1 was approved in BAL-002-WECC-1, that approval was predicated on
distributing burden and the availability of deliverability. 2 There has never been a technical study
proving that holding reserves more than that required under NERC BAL-002-X enhances the reliability
of the Western Interconnection.
By contrast, as variable generation is added to the Interconnection, there is increasing evidence that
holding excess reserves may be inhibiting reliability across the interconnection. FERC’s recent Order
901 echoes these concerns, addressing operational and performance concerns for variable resources.
Restated, within the Western Interconnection, applicable entities are holding more reserves than the
rest of the continent, even though there is no technical basis for doing so. In FERC Order 693, in which
NERC BAL-002-1 was first approved, at P341, FERC states:
341. We believe a continent-wide contingency reserves policy would assure [sic] that there are
adequate magnitude and frequency responsive contingency reserves in each Balancing

Order No. 672 at P 331. See also FERC Order 740, P 4 and P 23.
https://www.nerc.com/pa/Stand/Resources/Documents/FERC'S_Criteria_for_Approving_Reliability_Standards_fr
om_Order_672.pdf
2 FERC Order 740, Remand.
1

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WECC-0142 BAL-002-WECC-3—Contingency Reserve—Request to Retire
Authority. This will improve performance so that no Balancing Authority will be doing less than
its fair share.” (Emphasis added.)
By extension, retiring BAL-002-WECC-3 in favor of NERC BAL-002-3, ensures that no Balancing
Authority will be doing more than its fair share.
Further, requiring Balancing Authorities to hold that excess may be inhibiting the integration and use
of variable generation. As a result, BAL-002-WECC-3 creates a mandated scenario in which reserves are
used inefficiently and withheld from the marketplace.

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WECC-0142 BAL-002-WECC-3—Contingency Reserve—Request to Retire

Table of Contents
Introduction .............................................................................................................................................................5
Standard of Review ................................................................................................................................................6
Procedural History..................................................................................................................................................7
Development History (Pre-1996 to 2024) ............................................................................................................8
Structural Overview of BAL-002-WECC-3 ....................................................................................................... 11
Purpose ............................................................................................................................................................... 11
Applicability ...................................................................................................................................................... 11
Requirements ..................................................................................................................................................... 11
Requirement R1 ............................................................................................................................................. 11
Requirement R2 ............................................................................................................................................. 11
Requirement R3 ............................................................................................................................................. 12
Requirement R4 ............................................................................................................................................. 12
Reliability will be Maintained........................................................................................................................... 13
Vital Public Interests will be Enhanced .......................................................................................................... 18
Market Timing Issues ....................................................................................................................................... 18
Capacity Could be Better Utilized than Simply Holding Reserve .............................................................20
Conclusion ............................................................................................................................................................. 22

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Introduction
Per the Standard Authorization Request (SAR) for WECC-0142, 3 this document explores the full
retirement of WECC RRS BAL-002-WECC-3, Contingency Reserve.
The following will show that, if the standard is retired, reliability will continue to be maintained
through NERC BAL-002-3, and may be enhanced as resources being held for contingency reserves may
be used more efficiently to support variable generation.
By retiring BAL-002-WECC-3 in favor of NERC BAL-002-3:
•

Dispatchable resources can be used to support variable generation, addressing issues raised by
FERC in Order 901.

•

A more efficient use of resources should negate any current negative impacts on the market,
thereby enhancing vital public interests.

As the Procedural History and Development History sections note, BAL-002-WECC-3 is an evolution of
pre-standards originating in the 1990s. Never during the estimated 30 years of its existence has there
been a technical justification for the values and procedures required in the standard. Rather, the stated
values and procedures are the result of generalized negotiations taking place between the parties.
Because these values and procedures are negotiated, the content of BAL-002-WECC-3 is the lowest
common denominator and does not meet the requirements of FERC Order 672. 4
Because BAL-002-WECC-2a, Contingency Reserve, Request to Retire Requirement R2 provided the
technical support for retiring Requirement R2, arguments in that filing are not revisited here. 5

See WECC-0142 BAL-002-WECC-3, Contingency Reserve, Request to Retire, home page, at the SAR accordion.
FERC Order 672, P329 and P330.
5 Approved by the NERC Board of Trustees on August 15, 2019, filed with FERC on September 9, 2019.
3
4

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WECC-0142 BAL-002-WECC-3—Contingency Reserve—Request to Retire

Standard of Review
While the Commission may approve an RRS that is more stringent than a parallel continent-wide
standard, the Commission may also retire such a standard. 6
“While a Regional Entity may propose regional Reliability Standards that address specific,
unique regional conditions and circumstances, such regional Reliability Standards can be retired if
those justifications are no longer relevant. Accordingly, the Commission may approve retirement of
a more stringent regional requirement “if the Regional Entity demonstrates that the continentwide Reliability Standard is sufficient to ensure the reliability of that region.” 7 (Emphasis
added.)
In doing so, the Commission must give due weight to the technical expertise of a Regional Entity, like
WECC, that is organized on an interconnection-wide basis with respect to the regional differences
applicable to the Western Interconnection.
The technical qualifications of the subject matter experts compiling this paper are provided with this
filing, as presented and approved by the WECC Standards Committee (WSC).

The Commission approves regional differences proposed by Regional Entities, such as Regional Reliability
Standards and Variances, if the regional difference is just, reasonable, not unduly discriminatory or preferential,
and in the public interest. 16 U.S.C. § 824o(d)(2) and 18 C.F.R. § 39.5(a). (See also) Additionally, Commission
Order No. 672 requires further criteria for regional differences. A regional difference from a continent-wide
Reliability Standard must either be:
(1) more stringent than the continent-wide Reliability Standard, including a regional difference that addresses
matters that the continent-wide Reliability Standard does not; or is,
(2) necessitated by a physical difference in the Bulk-Power System.
7 Version One Regional Reliability Standard for Resource and Demand Balancing,
Order No. 740, 75 FR 65964 (Oct. 27, 2010), 133 FERC ¶ 61,063, P 30 (2010). See also: FERC, 18 CFR Part 40, Docket
No. RM19-20-000, WECC Regional Reliability Standard BAL-002-WECC-3 (Contingency Reserve), p.5
6

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WECC-0142 BAL-002-WECC-3—Contingency Reserve—Request to Retire

Procedural History
In 1996, the Western Systems Coordinating Council (WSCC) 8 adopted the WSCC Reliability Criteria,
Minimum Operating Reliability Criteria (MORC). The MORC prescribed levels of reserves that became
BAL-002-WECC-3, effective 2021.
In 1999, the MORC became the WECC Reliability Management System (RMS), a contract-based system
of accountability that pre-dated mandatory standards.
As the industry approached the onset of mandatory standards (2007) and memorialization of legacy
operating practices, the content of the RMS was adapted and approved as BAL-STD-002-0, Operating
Reserves (2007). That standard was an attempt to translate the substantive content of the RMS into the
sought-after NERC/FERC format of today’s reliability standards. The content was accepted “as is” with
its origins in the 1996 MORC; albeit, the early standard was remanded for remediation, largely on
format and structural grounds.
In 2013, FERC accepted remediations to BAL-002-WECC-2.
In 2017, an interpretation was added (BAL-002-WECC-2a), and later incorporated into BAL-002-WECC3, in which Requirement R2 was approved for retirement, with an effective date of August 15, 2019.
In 2025, the Western Interconnection still adheres to similar levels of reserves as it did in 1996. This
means that, for over 28 years, the Western Interconnection has held more reserves than the rest of the
continent (NERC BAL-002-3) even though there has never been technical justification to do so.

The Western Systems Coordinating Council (WSCC) was formed in 1967 by 40 power systems to coordinate the
planning and operations of the electric system in western North America. The WSCC's goal was to provide
reliable power to the public.

8

7

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WECC-0142 BAL-002-WECC-3—Contingency Reserve—Request to Retire

Development History (Before 1996 to 2024)
Before 1996, members of the WSCC voluntarily operated the Western Interconnection according to the
MORC. 9 Although the MORC contained provisions for generation control, generation performance,
and Contingency Reserve, the MORC provided no technical support for the reserve thresholds and
characteristics it set. 10 Rather, the operating thresholds were established by negotiation—not technical
analysis. If this approach were adopted today, FERC would likely deny approval of the standard as
contrary to FERC Order 672, P329. 11
In July and August of 1996, the Western Interconnection experienced two widespread outages resulting
from improper vegetation management. The resulting outage reports 12 13 made several
recommendations that would later be adopted in the 1999 WECC RMS. 14 15 The WECC Operating
Committee’s recommendation produced portions of the RMS that later evolved into WECC Standard
BAL-STD-002-0, Operating Reserves and, ultimately, BAL-002-WECC-3. Like the other initial

MORC, Maintenance Coordination: 1. Sharing information. The security and reliability of the interconnected
power system depends upon periodic inspection and adequate maintenance of generators, transmission lines and
associated equipment, control equipment, communication equipment, relaying equipment, and other system
facilities. Entities and coordinated groups of entities must establish procedures and responsibility for
disseminating information on scheduled outages and for coordinating scheduled outages of major facilities which
affect the security and reliability of the interconnected power system.
10 Minimum Operating Reliability Criterion, Section 1, Generation Control and Performance
11 FERC Order 672. P329. The proposed Reliability Standard must not simply reflect a compromise in the ERO’s
Reliability Standard development process based on the least effective North American practice—the so‐called
“lowest common denominator”—if such practice does not adequately protect Bulk‐Power System reliability.
Although the Commission will give due weight to the technical expertise of the ERO, we will not hesitate to
remand a proposed Reliability Standard if we are convinced it is not adequate to protect reliability.
12 The outage reports are available upon request. Western Systems Coordinating Council (WSCC) Disturbance
Report for the Power System Outage that Occurred on the Western Interconnection August 10, 1996, as approved
by the WSCC Operations Committee on October 18, 1996
13 “f. The WSCC Operations Committee shall assess whether the levels and allocation of operating reserves
contributed to the severity of this disturbance and implement corrective measures as appropriate.” Western
System Coordinating Council Disturbance Report, For the Power System Outages that Occurred on the Western
Interconnection on 2 JUL 1996. Approved by the WSCC Operations Committee on September 19, 1996. RMS
Outage Report, page 14.
14 The RMS was approved 1 SEP 1999. WECC Comment Report – WECC Tier 1- RMS Standard – (BAL-STD-002-0)
Question 4, Attachment 2, page 9.
15 “The majority of these standards were specifically developed to address and mitigate main causes of the two
major system outages that occurred in the Western Interconnection in July and August of 1996.” Agenda Item 3,
Board of Trustees Meeting, March 12, 2007, page 4
9

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WECC-0142 BAL-002-WECC-3—Contingency Reserve—Request to Retire
standards, the language of the original standard was a translation of the language contained in the
RMS. 16
In March 1997, noting that federal remedial legislation could take years to enact, the WSCC trustees
created the WSCC RMS Policy Group 17 establishing a contract-based operational system known as the
RMS. 18 19 In establishing the RMS, the WSCC RMS Policy Group reviewed all NERC and WECC
reliability criteria, identified specific criteria deemed critical for reliability management, then moved
those criteria into the RMS through a three-phase implementation plan. 20
On April 14, 1999, FERC asserted jurisdiction over the RMS.
Between September 1998 and February 2000 (phase two of the three-phase RMS implementation), the
WSCC turned the content of the RMS into the first mandatory reliability standards (aka Version Zero,
2007). BAL-SDT-002-0, Contingency Reserve was part of that translation.
On December 22, 2006, WECC submitted a request to NERC to approve, and send to FERC for
approval, eight proposed RRSs. WECC referred to the eight proposed standards as its Tier One

WECC states that the proposed regional Reliability Standards, which are exact translations of existing regional
criteria, either address matters not addressed in the Commission-approved ERO Reliability Standards or contain
more stringent requirements than the ERO standards. (FERC accepted Tier One standards evolving from the
RMS. AKA: Tier One Order.) FERC, 119 FERC ¶ 61,260 United States of America, Federal Energy Regulatory
Commission, Order Approving Regional Reliability Standards for the Western Interconnection and Directing
Modifications (Issued June 8, 2007), page 19.

16

Following the enactment of EPAct 2005 and the establishment of mandatory Reliability Standards applicable to
all owners, operators, and users of the BPS, WECC sought to translate certain of its existing practices under its
RMS reliability criteria into regional Reliability Standards to supplement the continent-wide Reliability Standards
the Commission approved in Order No. 693. To that end, WECC established a task force to identify criteria in the
RMS that should be binding on all BPS users, owners, and operators in the Western Interconnection, not just the
Transmission Operators subject to the RMS. The task force chose eight of the identified criteria, which had the
highest priority and could be implemented in the near term for translation into regional Reliability Standards.
United States of America Before the Federal Energy Regulatory Commission, North American Electric Reliability
Corporation (NERC), Docket No. RM16-10-000, Supplemental Information for Petition of the NERC and WECC
for Approval of retirement of Regional Reliability Standard TOP-007-WECC-1a, page 5.

17

18

Hearing

Electric Reliability Corporation, Helping Owners, Operators, and Users of the Bulk Power System Assure
Reliability and Security for More Than 50 Years, By David Nevius, Senior Vice President 1979–2012, Page 40-41.

19

20

Hearing

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WECC-0142 BAL-002-WECC-3—Contingency Reserve—Request to Retire
standards originating from the RMS because the proposed standards were translations of standards
that were already mandatory within the Western Interconnection as part of the RMS. 21
Those eight standards—that included Tier One WECC-BAL-STD-002-0 (Operating Reserves)—were
near-exact translations of existing WECC criteria that FERC earlier accepted as part of the WECC RMS
program. 22 Because the content was a near-exact translation, the format did not match that required by
NERC/FERC. This would later lead to a remand of BAL-002-WECC-1 to ensure conformity.
On January 9, 2007, NERC provided WECC with a report of its preliminary findings about the request
from December 22, 2006, and provided WECC with a list of required remediations. 23 The request
largely addressed styles, formats, and corrections to compliance sections. The NERC Board of Trustees
approved the Tier One request subject to remediation and sent the eight proposed standards to FERC
with a request for approval.
In June 2007, FERC approved WECC’s submittal of eight reliability-crucial Tier One standards, thereby
transitioning from the RMS system to that of FERC-approved NERC Reliability Standards. 24 Although
earlier versions lacked technical support, FERC agreed with
“WECC, WIRAB [Western Interconnection Regional Advisory Board] and NERC that
approval of [WECC’s early BAL] under section 215 would enhance reliability in the
Western Interconnection by making WECC’s current practices binding on all relevant
entities in the region and by strengthening WECC’s compliance and enforcement
authority.” 25

North American Electric Reliability Corporation, Docket No. RR07-___-000, III. BACKGROUND ON THE
DEVELOPMENT OF THE WECC REGIONAL RELIABILITY STANDARDS, Debra A. Palmer of Schiff/Hardin
(1666 K STREET N.W., SUITE 300, WASHINGTON, DC 20006) on March 26, 2007.
22 Loc. Cit. IV. Overview of the Proposed WECC Regional Reliability Standards, page 6.
23 NERC DECISION APPROVING, WITH CONDITIONS, RELIABILITY STANDARDS PROPOSED BY
WESTERN ELECTRICITY COORDINATING COUNCIL, page 2. (Approved by Board of Trustees March 12,
2007)
24FERC Order Approving Regional Reliability Standards for the Western Interconnection and Directing
Modifications, Docket No. RR07-11-000, (Issued June 8, 2007)
25 Tier One Order, p. 43. See also, “The proposed regional Reliability Standards would make eight of those RMS
criteria binding on the applicable subset of users, owners and operators of the Bulk-Power System in the United
States portion of the Western Interconnection, as identified in each proposed standard. The regional Reliability
Standards would supplement rather than replace the Commission-approved Reliability Standards developed by
the ERO that will take effect in June 2007. Tier One, p. 10.
21

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WECC-0142 BAL-002-WECC-3—Contingency Reserve—Request to Retire

Structural Overview of BAL-002-WECC-3
Purpose
The Purpose of currently effective RRS BAL-002-WECC-3—Contingency Reserve is to provide an RRS
specifying “the quantity and types of Contingency Reserve required to ensure reliability under normal
and abnormal conditions.” 26
The NERC Glossary defines Contingency Reserve as:
“The provision of capacity that may be deployed by the Balancing Authority to respond to a Balancing
Contingency Event and other contingency requirements (such as Energy Emergency Alerts as specified
in the associated EOP standard). A Balancing Authority may include in its restoration of Contingency
Reserve readiness to reduce Firm Demand and include it if, and only if, the Balancing Authority:
•

is experiencing a Reliability Coordinator declared Energy Emergency Alert level and is utilizing
its Contingency Reserve to mitigate an operating emergency in accordance with its emergency
Operating Plan.

•

is utilizing its Contingency Reserve to mitigate an operating emergency in accordance with its
emergency Operating Plan.”

Applicability
BAL-002-WECC-3 applies to Balancing Authorities (BA), unless the BA is a member of a Reserve
Sharing Group (RSG), in which case the RSG becomes the applicable entity.

Requirements
The standard consists of four requirements.
Requirement R1
•

Provides that each BA and RSG must maintain a minimum amount of Contingency Reserve,
except within the first sixty minutes following an event requiring the activation of Contingency
Reserves, and that the Contingency Reserve must consist of any combination of a list of
specified reserve types.

Requirement R2
•

26

Reserved. Retired, subject to cyclical field tests.

BAL-002-WECC-3, Contingency Reserve, Purpose.

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WECC-0142 BAL-002-WECC-3—Contingency Reserve—Request to Retire
Requirement R3
•

Each Sink BA and RSG must maintain an amount of Operating Reserve, in addition to the
minimum Contingency Reserve in Requirement R1, equal to the amount of Operating Reserve–
Supplemental for any Interchange Transaction designated as part of the Source Balancing
Authority’s Operating Reserve–Supplemental or source Reserve Sharing Group’s Operating
Reserve–Supplemental, except within the first sixty minutes following an event requiring the
activation of Contingency Reserve.

Requirement R4
Each Source BA and RSG must maintain an amount of Operating Reserve, in addition to the
minimum Contingency Reserve amounts identified in Requirement R1, equal to the amount
and type of Operating Reserves for any Operating Reserve transactions for which it is the
Source BA or RSG.

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WECC-0142 BAL-002-WECC-3—Contingency Reserve—Request to Retire

Reliability will be Maintained
Upon retirement of BAL-002-WECC-3, reliability will be maintained by NERC BAL-002-3, Disturbance
Control Standard—Contingency Reserve for Recovery from a Balancing Contingency Event, reinforced
by the enhanced availability of resources currently unavailable under BAL-002-WECC-3.
Replacing BAL-002-WECC-3 with NERC BAL-002-3 Mitigates Reliability Gaps associated
with Variable Generation
As highlighted by FERC in its Order 901, with the growing amount of variable generation replacing
more responsive and dispatchable resources, the industry faces the dilemma of how to support these
new resources. 27 Unlike traditional resources, much of the new variable generation cannot be quickly
dispatched, thus creating a gap in reliability. FERC acknowledged that gap, noting that neither
business-as usual nor existing reliability standards will remedy this concern. Finally, FERC also
recognizes the value that steps taken must apply on a continent-wide basis. 28
Replacing BAL-002-WECC-3 with the continent-wide NERC BAL-002-3 takes immediate steps towards
meeting FERC’s concerns.
In Order 901, FERC states:
“[W]e continue to find that as the resource mix trends towards higher penetrations of IBRs, the
need to reliably integrate these resources into the Bulk-Power System is expected to grow, and
that the currently effective Reliability Standards do not adequately address IBR reliability risks.
The continuing risks that the increasing penetration of IBRs pose to the reliable operation of the BulkPower System underscore the need for mandatory Reliability Standards to address these issues on a
nationwide basis.” (Emphasis added.) Order 901, P24.
When BAL-002-WECC-3 is retired and replaced with NERC BAL-002-3, the amount and type of
reserves required to be held back within the Western Interconnection will decrease. That frees those
resources to be plied against load. Within the Western Interconnection, a vast majority of these
sequestered resources are immediately dispatchable (such as hydro), thus serving as the perfect
resource to match the less predictable response of variable generation.

FERC Order 901, P11-15, 185 FERC ¶ 61,042, United States of America, Federal Energy Regulatory Commission
(FERC), 18 CFR Part 40, Docket No. RM22-12-000; Reliability Standards to Address Inverter-Based Resources,
October 19, 2023. Hereafter: Order 901
28 Order 901, P24.
27

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WECC-0142 BAL-002-WECC-3—Contingency Reserve—Request to Retire
By making these dispatchable resources more operationally available, the secondary benefits may be to
bolster the supply of generation to the market. This potential secondary benefit directly addresses vital
public interests. 29
Dispatchable Resources Contribute Significantly to Essential Reliability Services (ERS) 30
ERSs consist of frequency control, ramping capability, and voltage control.
Frequency control is necessary because the electric grid is designed to operate at a frequency of 60 hertz
(Hz). Deviations from 60 Hz can have destructive effects on generators, motors, and equipment of all
sizes and types. It is critical to maintain and restore frequency after a disturbance such as the loss of
generation. This requires an instantaneous (inertial) response from some resources and a fast response
from other resources to slow the rate of fall during the arresting period, a fast increase in power output
during the rebound period to stabilize the frequency, and a more prolonged contribution of additional
power to compensate for lost resources and bring system frequency back to the normal level. Two
NERC Reliability Standards address this:
•

BAL-002-3 Disturbance Control Standard—Contingency Reserve from a Balancing Contingency
Event

•

BAL-003-2 Frequency Response and Frequency Bias Setting

Adequate ramping capability (the ability to match load and generation at all times) is necessary to
maintain system frequency. Changes to the generation mix or the system operator’s ability to adjust
resource output can impact the ability of the operator to keep the system in balance. NERC Reliability
Standard BAL-001-2 (Real Power Balancing Control Performance) addresses this issue.
Voltage must be controlled to protect system reliability and move power where it is needed in both
normal operations and following a disturbance. Voltage issues tend to be local in nature, such as in
sub-areas of the transmission and distribution systems. Reactive power is needed to keep electricity
flowing and maintain necessary voltage levels. Several NERC Reliability Standards address voltage
control.
Restated, replacing BAL-002-WECC-3 with NERC BAL-002-3 frees dispatchable resources to address
FERC-identified reliability gaps created by variable generation, and may bolster vital public interests.

“335. Finally, we understand that at times development of a proposed Reliability Standard may require that a
particular reliability goal must be balanced against other vital public interests, such as environmental, social, and
other goals. We expect the ERO to explain any such balancing in its application for approval of a proposed
Reliability Standard. “ (Emphasis added.) Order 693, P35.
30 “Essential Reliability Services (ERS) are the elemental ‘reliability building blocks’ from resources (generation
and demand) necessary to maintain Bulk Power System (BPS) reliability.” NERC ERS Task Force – Scope – 2014.
29

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WECC-0142 BAL-002-WECC-3—Contingency Reserve—Request to Retire
Because adequate levels of reserves are established in NERC BAL-002-3, and supported by BAL-003-2,
BAL-002-WECC-3, Requirements R1 through R4 are not needed.
Replacing BAL-002-WECC-3 With NERC BAL-002-3 Provides Sufficient Reserves at a
Continent-Wide Level
In the earliest stages of the Western Interconnection’s strides to establish adequate Contingency
Reserves, the applicable entity’s reserves were established by BAL-STD-002-0, Operating Reserves, at
5% of hydro generation and 7% thermal generation (50% spinning and 50% non-spinning). 31 These
thresholds were not technically supported; they were the result of contractual negotiations. Today,
such a standard would likely not be approved by FERC as violative of the principles established in
FERC Order 672. (See foot note 2.)
As BAL-STD-0-2 was replaced with later iterations of that standard, the result was today’s BAL-002WECC-3, in which the Responsible Entity’s reserves are set at:
R1.1.1 “The greater of either:
•

The amount of Contingency Reserve equal to the loss of the most severe single contingency; 32
(or)

•

The amount of Contingency Reserve equal to the sum of three percent of hourly integrated
Load plus three percent of hourly integrated generation.”

Bullet one of BAL-002-WECC-3 describes the Most Severe Single Contingency, or MSSC.
The MSSC ensures that all entities can recover Area Control Error (ACE) within 15 minutes. The MSSC
serves as the upper Contingency Reserve threshold for all interconnections, except the Western
Interconnection. Within the Western Interconnection, the levels of reserve set by BAL-002-WECC-3 can
exceed that of the rest of the continent that is protected by FERC-approved BAL-002-3. As a result, the
Western Interconnection carries an excess of reserve that exacerbates concerns raised by FERC in Order
901 wherein FERC addresses the need for continent-wide standards to backstop the operational
performance of variable generation. Comparing NERC BAL-002-3 with BAL-002-WECC-3 illustrates
this outcome.
NERC BAL-002-3 states that the BA and the RSG are not subject to compliance with BAL-002-3, R1 for
multiple events that exceed the MSSC. NERC BAL-002-3 requires the applicable entity to deploy
Contingency Reserve up to its MSSC; however, it does not require Contingency Reserve deployment
beyond MSSC.

See Attachment - Transition from 5-7 to 3-3, as described in 2005 by Merrill Schultz; see also Attachment History of WECC Reserve 5-7 Spin Merrill Schultz, March 3, 2005; see also BAL-STD-002-0, Operating Reserves.
32 Also known as the Most Severe Single Contingency (MSSC).
31

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WECC-0142 BAL-002-WECC-3—Contingency Reserve—Request to Retire
By contrast, BAL-002-WECC-3 requires the applicable entity to maintain a level of Contingency
Reserves exceeding that required under NERC BAL-002-3, as approved by FERC. Specifically, BAL-002WECC-3, Requirement R1 requires the applicable entity to carry reserves that equal or exceed the
entity’s MSSC—beyond that required by BAL-002-3 that adequately serves the balance of the continent.
Among other things, this means these valuable dispatchable resources in excess of the MSSC cannot be
used to meet FERC’s goal of backstopping variable resources as identified in FERC Order 901.
While application of BAL-002-3 could free resources to enhance reliability, application of BAL-002WECC-3 can inhibit reliability when resources are withheld that could otherwise serve load and
backstop variable resources.
For example:
Using historical data from January 2020 - May 2024, comparison of the hourly Contingency Reserve
Requirement (calculated using 3% generation and 3% load) to the Most Severe Single Contingency
(MSSC), the results identified there was more than 5,000 MW of capacity available during the
summertime peak hours and between 2,000-2,500 MW during the remaining hours of the year. See
figure below.

Figure 1: Reserves in excess of MSSC

The Shortened Execution Time of BAL-002-WECC-3 Inhibits Reliability Due to Market
Rules in the Western Interconnection
BAL-002-WECC-3, Requirements R3 and R4 require the applicable entity to restore Contingency
Reserve within 60 minutes of the initiating event. By contrast, BAL-002-3 requires the applicable entity
to achieve the same task in 105 minutes. As a result, BAL-002-WECC-3 requires the performance of the
same task 45 minutes earlier than its continent-wide counterpart. This shortened period inhibits
reliability in that it forces the applicable entities into transactions agreed upon during an arbitrarily
shortened time window. Like BAL-002-3, Requirement R1., there is no technical support suggesting

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WECC-0142 BAL-002-WECC-3—Contingency Reserve—Request to Retire
that rushing this transaction enhances reliability—yet it remains in force 28 years after its inception,
still lacking any technical support.
Further, the restoration of reserves in a 60-minute timeframe is restrictive on the entity’s ability to
secure additional resources within the established business practices in the region. The NERC Standard
of up to 105 minutes (90 minutes after the 15 minutes Contingency Recovery Period) after the event has
less commercial impact and is acceptable from both a commercial standpoint as well as an operational
standpoint.
The WECC requirement of 60 minutes from start of a DCS event restricts the deficient entity from
rescheduling resources to replace those that were lost during the event. Western market practices
require schedules to be submitted and approved well in advance to ensure reliability, and once the
schedule windows close, it is difficult to make last-minute changes. Before markets, when transactions
were bilateral, a recovery of generation resources was more flexible, and could be more quickly
executed.
The NERC BAL-002-3 Contingency Reserve Restoration Period of up to 105 minutes allows applicable
entities to use normal market scheduling practices to replace lost generation. FERC’s approval of NERC
BAL-002-3 shows its belief that the NERC standard of 105 minutes (90 plus 15) is adequate and does
not degrade reliability.
In attempting to meet the 60-minute restoration requirement, the applicable entity has two options.
First, the BA must carry significantly more Contingency Reserve than is required to maintain an
adequate level of reliability, or second, be prepared to enter an Energy Emergency Alert 3 which allows
the BA to deploy Contingency Reserves to serve load. By definition, entering into an Energy
Emergency Alert is an indication of reduced reliability. Given normal scheduling practices, a 90-minute
restoration time allows a Responsible Entity to restore Contingency Reserve using normal established
market scheduling practices.
In addition, many entities own BES equipment in more than one interconnection. Having a single
standard enhances these entities’ ability to stay in compliance with the standard using consistent
business practices across the interconnections.
Reserve Thresholds do Not Reflect Resource Mix
Due to the changing resource mix and the proliferation of renewable generation, battery storage, and
retirements of conventional synchronous generation, resource adequacy has become a serious concern.
The BAL-002-WECC standard unnecessarily ties up significant generation which is dispatchable,
frequency responsive and fast ramping. Generation that could be used to meet ramps, follow variable
resources, or simply meet expected loads, is committed to contingency reserve capacity that is not
available to serve load. For example, Western Power Pool’s Northwest Power Pool Reserve Sharing
Group Northwest-Montana zone typically has a 1,200 MW MSSC, yet routinely has over 3,000 MW of
17

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WECC-0142 BAL-002-WECC-3—Contingency Reserve—Request to Retire
reserves being held under the 3/3 requirement. That available capacity, usually in excess 1,800 MW,
could be used to meet other reliability related services obligations. The existing 3/3 contingency reserve
requirement results in the construction of at least 1800 MW of excess generation in the NorthwestMontana zone. The ability to use this generation capacity exceeding the MSSC will also allow entities to
efficiently operate their facilities. Idled excess capacity will be reduced and productive generation
increased.
Under NERC standard NERC BAL-002-3, the Eastern, Texas and Quebec Interconnections operate
without the additional reserve requirement (3% load and 3% generation), and they are allowed to
restore their reserves within 90 minutes. The changing market structure in the Western Interconnection
has made it difficult to fully restore the required reserves within 60 minutes due to market scheduling
timelines. This can lead to implementation of emergency procedures, typically Energy Emergency Alert
3 conditions, due to an energy shortfall precipitated by the 60-minute recovery period. When the
Western markets were mostly bilateral, the 60-minute recovery was consistent with energy scheduling
protocols. Market integration has altered energy scheduling protocols making it very difficult to
modify schedules within 60 minutes of a generation contingency. For these reasons BAL-002-WECC-3
has become obsolete, while not enhancing reliability.
Reserves are unused or unloaded generation that are in a state of readiness in case there is sudden loss
of loaded generation. When reserves are held above the MSSC, as they are in the Western
Interconnection, excess capacity must be built that has no other reliability benefit. Every energy
customer in the West absorbs this excess cost. Retirement of BAL-002-WECC-3 reallocates these excess
resources to the benefit of the interconnection in the form of dispatchable, responsive, and available
resources to reliably integrate future variable resources, such as wind, solar, and other renewable
resources.

Vital Public Interests will be Enhanced 33 34
Market Timing Issues
The emergence of organized markets in WECC, since the inception of BAL-002-WECC-1 has brought a
new dynamic in the timing and means by which the reserves are procured. The number of participants
in the California ISO Energy Imbalance Market (AKA: Western Energy Imbalance Market, or WEIM)

“Finally, we understand that at times development of a proposed Reliability Standard may require that a
particular reliability goal must be balanced against other vital public interests, such as environmental, social, and
other goals. We expect the ERO to explain any such balancing in its application for approval of a proposed
Reliability Standard.” FERC Order No. 672 at P 335.
34 “The proposed Reliability Standard does not necessarily have to reflect the optimal method, or “best practice,”
for achieving its reliability goal without regard to implementation cost or historical regional infrastructure design.
It should however achieve its reliability goal effectively and efficiently.” FERC Order No. 672 at P 328.
33

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WECC-0142 BAL-002-WECC-3—Contingency Reserve—Request to Retire
has grown significantly in the past several years. CAISO EIM market rules require a participating BA to
balance its resources and loads 75 minutes before the next operating hour (T-75). Failure to do this can
result in financial penalties to the participating BA. This rule has had the effect of discouraging any
bilateral energy trading after T-75 and does not align well with a 60-minute reserve recovery time limit.
No bilateral trading for replacement energy reserve is possible for the next operational hour because
participating WEIM BAs cannot participate in trades within T-75.
This leaves the contingent BA in a resource short position when the 60-minute contingency restoration
time expires. At this point, the contingent BA must activate emergency operating procedures up to
asking the Reliability Coordinator to declare an EEA3, including load shedding to balance the
contingent BA. By extending the contingency restoration time to 105 minutes (15-minute recovery plus
90-minute restoration), the contingent BA has at least 30 minutes to arrange replacement energy in a
bilateral manner from other BAs or schedule their own resource in the WEIM. The additional
contingency reserve recovery time allows the contingent BA to make orderly and planned adjustments
and continue to serve firm load without the implementation of emergency operating procedures, up to
and including shedding firm load.
FERC and the industry have determined that 90 minutes from the end of the recovery period (up to 15
minutes) is sufficient to maintain an adequate level of reliability. The shorter restoration period in the
WECC creates artificial reliability issues as the applicable entity tries to rebalance supply and demand
in an arbitrarily shorter period than that required in the NERC BAL-002-3.
To give a clear understanding of the impact of either option, the following example is provided.
Assume the NWPP RSG’s MSSC is approximately 1,200 MW. Under BAL-002-WECC-3, the NWPP RSG
would normally carry approximately 2,200-4,000 MW of Contingency Reserves depending on the time
of year. Assuming the MSSC occurs, the NWPP RSG would activate 1,200 MW of its reserves and
restore the ACE to the pre-event level. Members now have approximately 60 minutes to restore 1,200
MW of reserves while still carrying more than 1,000–2,800 MW, which is greater than the MSSC,
assuming it was not reduced with the loss of the 1,180 MW event. See figure below.

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WECC-0142 BAL-002-WECC-3—Contingency Reserve—Request to Retire

Figure 2: Reserves in excess of MSSC; January 1, 2020, through May 1, 2024

As discussed earlier, due to market rules related to the WEIM in which most entities are taking part,
new resources cannot be added to an entity’s reserves for the next hour (minimum time to add a
resource under the WEIM (75 minutes), or other emerging markets. If a resource is not already in the
WEIM, it cannot count toward the reserves needed. So, an entity must have already been carrying
reserves greater than required under the WECC standard, or it must reduce load to balance its
resources and loads including reserves. (It can be argued that by reducing loads, you are putting the
interconnection at greater risk because you have removed one available resource, the load, from being
an option for the next event.) To avoid the declaration of an EEA, the NWPP would need to carry an
additional 1,000 MW above the required reserves or declare an EEA any time the reserves need to be
restored within 60 minutes of the event.
When entities withhold extra reserves to avoid the EEA, this paradigm keeps 2,500 to 4,000 MW from
serving load due to the WECC current standard, which has no technical merit, as compared to the
NERC Standard. These additional resources could be used to help integrate more inverter-based
resources and serve loads more efficiently if it were available for load service.
Entering an Energy Emergency Alert indicates reduced reliability. Given normal scheduling practices,
which require bilateral schedules to be completed and approved 75 minutes before the hour, a 60minute restoration time does not allow adequate time for a Responsible Entity to restore Contingency
Reserve in less than 60 minutes from the initiating event, potentially resulting in an Energy Emergency
Alert situation.

Capacity Could be Better Used than Simply Holding Reserve
FERC and the industry have determined that the amount of Contingency Reserve needed to maintain
an adequate level of reliability is the amount of Contingency Reserve needed to replace the MSSC
resource. Holding Contingency Reserve more than MSSC precludes using operating reserve for other
purposes, particularly load and resource balancing in real-time. As the grid transitions from

20

<Limited-Disclosure>

WECC-0142 BAL-002-WECC-3—Contingency Reserve—Request to Retire
conventional synchronous generation to more variable renewable resources, increasing capacity will be
needed to manage the variability and faster ramping requirement of these resources. Allocating
reserves in excess of that needed to maintain an adequate level of reliability, or MSSC, ultimately
detracts from reliability.

21

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WECC-0142 BAL-002-WECC-3—Contingency Reserve—Request to Retire

Conclusion
Retirement of BAL-002-WECC-3 Contingency Reserve would reduce required reserves in WECC
without diminishing the ability to meet the deployment requirement. Freeing up reserves from the
Contingency Reserve requirement would increase the resources available to manage variable resources
and accommodate increased renewable resource integration.
The existing BAL-002-WECC-3 Contingency Reserve sets a BA’s or RSG’s Contingency Reserve
requirement to the greater of the MSSC or 3% of the applicable entity’s generation and 3% of its load.
This 3/3 requirement exceeds MSSC for most responsible entities.
By contrast, NERC Standard BAL-002-3 Disturbance Control Standard—Contingency Reserve for
Recovery from a Balancing Contingency Event, Requirement R1.3.2 states that the BA/RSG is not
subject to compliance with Requirement R1 for multiple events that exceed the MSSC. NERC BAL-0023 requires the applicable entity to deploy Contingency Reserve up to the MSSC but does not require
Contingency Reserve deployment beyond the MSSC.
In BAL-002-3, FERC and the industry have determined that the amount of Contingency Reserve
needed to maintain an adequate level of reliability is the amount of Contingency Reserve needed to
replace the MSSC resource.
Holding Contingency Reserve more than MSSC precludes using operating reserve for other purposes,
particularly load and resource balancing in real time. As the grid transitions from conventional
synchronous generation to more variable renewable resources, increasing capacity will be needed to
manage the variability and faster ramping requirement of these resources. Allocating reserve in excess
of that needed to maintain an adequate level of reliability, or MSSC, ultimately detracts from reliability.
BAL-002-WECC-3 requires an applicable entity to restore Contingency Reserve within 60 minutes of
the initiating event (as opposed to up to 105 minutes in BAL-002-3), or 45 minutes sooner than required
by BAL-002-3. With respect to impacts to the time to restore Contingency Reserve, FERC and the
industry have determined that 90 minutes from the end of the recovery period (up to 15 minutes) is
sufficient to maintain an adequate level of reliability. By contrast, the 60-minute requirement within
BAL-002-WECC-3 creates potential reliability issues as an applicable entity tries to rebalance in an
arbitrarily shorter period than that required in the NERC BAL-002-3. In attempting to meet the 60minute restoration requirement, an applicable entity has two options. First, the BA must carry
significantly more Contingency Reserve than is required to maintain an adequate level of reliability, or
second, be prepared to enter an Energy Emergency Alert 3 and deploy Contingency Reserve to serve
load. Given normal scheduling practices, a 90-minute restoration time allows an applicable entity to
restore Contingency Reserve without employing emergency procedures.
Retirement of BAL-002-WECC-3 will enhance the reliable operation of the Western Interconnection by
allowing resources that are presently used for overprotecting above the MSSC to be available to meet
22

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WECC-0142 BAL-002-WECC-3—Contingency Reserve—Request to Retire
the immediate balancing needs of the Interconnection. This will free those resources to be used as
needed in a rapidly changing system to maintain overall reliability.

23

Response to AZPS from NERC 45-day Comment Period
WECC-0142 Drafting Team
November 21, 2025

Background
After the NERC 45 day comment period closed, NERC legal reached out to the WECC Standards
department and recommended that a response be prepared by WECC and the WECC-0142 Drafting
team to a comment submitted by AZPS.
WECC Staff scheduled and publicly noticed a Drafting Team meeting with the intent of addressing the
comment. The Drafting Team met, discussed the comment, and provides the following response.

AZPS Comment
“AZPS does not agree with the request to retire BAL-002-WECC-3 in its entirety. From 2019 to 2024, the
Western Interconnection has experienced several significant events impacting the Bulk Electric System
such as extreme natural events, inverter-based resource events, and resource adequacy that may have
benefited from having additional reserves to respond to contingency events. The more stringent criteria
in BAL-003-WECC-3 may have alleviated some of these events.”

Response
AZPS is reasonable in expressing caution and the DT offers the following response:
WECC and NERC’s position is supported by data and regulatory precedent.
•

The continent-wide standard is sufficient.

•

There is no technical evidence that the extra reserves improve reliability.

•

Maintaining excess Contingency Reserves reduces system flexibility.

The Drafting Team acknowledges AZPS’s comments, but the technical and regulatory consensus
supports retirement—unless new studies show otherwise.

Drafting Team Meeting and AZPS Participation
It is worth noting that during the Drafting Team meeting multiple employees of AZPS were present and
active on the call. This included the employee that submitted the comment and the manager of that
employee. They were able to provide some background information and some context on why the
comment was submitted and ultimately accepted the Drafting Teams response to the comment during
the meeting. Meeting minutes are available for that meeting if needed.

E LECTRIC R ELIABILITY AND S ECURITY F OR THE W EST

From:
Bcc:
Subject:
Date:
Attachments:

Crane, Donovan
Standards Information; Ahmad, Syed; Ashbaker, Steve; Conway, Kevin; Crane, Donovan; DiFabio, ChaRee; Hydzik, Richard;
Loutan, Clyde; McLean, C.D.; McManus, Bart; Miremadi, Ali; Pfeister, Mike; Wahlstrom, Alan
WECC-0142: Request to Retire BAL-002-WECC-3, Contingency Reserve Notice of Ballot
Friday, April 11, 2025 11:36:00 AM
image001.png

Project WECC-0142 – Notice of Ballot Pool Formation and Ballot
Background
On March 06, 2025 the WECC Standards Committee (WSC) approved the project WECC0142: Request to Retire BAL-002-WECC-3, Contingency Reserve drafting team’s request to
put the project out for industry ballot. This project comes from a request that the Reliability
Standard BAL-002-WECC-3 be retired in its entirety. The drafting team has written a white
paper with justification to do so, and this white paper was put out for industry comment.
The result of that comment period was 100% support for the retirement of the Standard
based on the rationale presented in the white paper. The white paper, comment period
responses and other supporting documents can be found on the WECC-0142 project page.
While the WECC IT team works to implement the new balloting software that will be used
with the new WECC website that came online in 2024, the process for balloting WECC-0142
will be different than previous balloting processes. This interim balloting process will still
conform to the WECC Reliability Standards Development Procedures (RSDP).
WECC-0142 Balloting Timeline
The following schedule applies to the project:
April 13th – 28th the ballot pool will be open and members of the WECC Ballot Body
interested in participating in the Ballot can join the Ballot Pool.
April 30th a standards briefing meeting will be held for any clarifying questions before the
Ballot opens. Information about this meeting will be provided separately and found on the
calendar on the WECC website as well.
May 1st – 15th the Ballot will be open, and members of the ballot pool will have the
opportunity to cast their vote and provide narrative feedback. The Ballot will be scheduled
to close at 6 p.m. MDT on May 15th, 2025.
After this, WECC Staff will compile the votes and narratives and send out notice of the
outcome of the Ballot
WECC-0142 Balloting Process
The Balloting Process will have the following steps.
1. 4/11/2025 - WECC Standards staff will send an email notification to the Standards

Distribution list with the balloting information and process with a solicitation for
current Ballot Body members to join the pool. This is that notification.

2. 4/13/2025 – Ballot Pool Formation Opens - To join the pool an interested member of

the Ballot Body must send an email to [email protected] with the following
information that can be validated against the Ballot Body
a. Their Name,
b. Their Entity’s Name,
c. Sector(s) they are joining under
d. Stated interest in joining the WECC-0142 Ballot Pool
3. 4/28/2025 6:00 p.m. MDT – Ballot Pool Closes
4. 4/30/2025 - WECC Standards staff will facilitate the Standards Briefing call
5. WECC Staff will send another email notification to the formed ballot pool for a

reminder on when and how to cast their votes once the Ballot Pool formationcloses
and the Standards briefing call is complete.

6. Standards Staff will have WECC IT open a button on the WECC Regional Standards

Voting web page.

7. 5/1/2025 – Ballot Voting Opens - Those who have registered for and been validated to

be part of the Ballot Pool will cast their votes.

8. 5/15/2025 6:00 p.m. MDT – Ballot Voting Closes

Procedural Notes
The RSDP state the following when it comes to noticing the Ballot and forming the discrete
Ballot Pool from the larger Ballot Body:
“Notice that a Ballot Pool is forming will be sent via the SEL and posted to the WECC
website. That notice shall contain, at a minimum, the following information:
1. Identification of the RRS or CRT;
2. The proposed action to be taken (e.g., Notice of Ballot Pool Formation / Notice of Ballot);
3. When the Ballot Pool will open and close;
4. When the ballot will take place;
5. How to cast a vote; and,
6. The WECC website location of the proposed RRS or CRT and related documents for
review. “
As well as
“Applications received less than five days prior to the opening of a Ballot Pool may not be
considered for inclusion in that Ballot Pool unless specifically allowed by the Director of
Standards (DOS).”
Both of these statements can be found on page 14 of the Reliability Standards Development
Procedures found on WECC’s website.
Please reach out to me with any questions or comments that you may have.
Donovan Crane
Senior Engineer, Standards Development
Phone (385) 408-9296
www.wecc.org

<Public>

Unofficial Comment Form
WECC-0142
Request to Retire BAL-002-WECC-3,
Contingency Reserve
Posting for Comment 1

Do not use this form for submitting comments. Use the hyperlink or Submit Comments button under
the “Submit and Review Comments” accordion on the project page to submit comments on Project
WECC-0142 - Request to Retire BAL-002-WECC-3, Contingency Reserve by 6:00 pm (Mountain)
January 15th, 2025.
All documents associated with the project and posting can be found on the Project Page under the
“Posting 1 for Comment” accordion. If you have questions, please contact Donovan Crane, Senior
Engineer, Standards.
Background Information
This project is a request to retire BAL-002-WECC-3 in its entirety. The Drafting Team has put together a
white paper that details the rationale for retiring BAL-002-WECC-3 and is soliciting comments about
that paper. The hope is to get feedback, gauge support, and then prepare to submit the request to
NERC to retire the Standard.
Questions
1. Do you agree with the Drafting Team's request for the Standard to be retired? Yes/No with a
narrative explanation.
2. Do you agree with the Drafting Team's rationale for requesting the retirement of the Standard?
Yes/no with a narrative explanation
3. Do you have any other rationale that the drafting team may not have thought of or included in
this document? Yes/No with a narrative explanation

155 North 400 West | Suite 200 | Salt Lake City, Utah 84103
www.wecc.org

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Response to Comments
Posting 1
11/15/2024 through 01/15/2025
WECC-0142: Request to Retire BAL-002-WECC-3,
Contingency Reserve

Posting 1
The WECC-0142: Request to Retire BAL-002-WECC-3, Contingency Reserve Drafting Team (DT) thanks
everyone who submitted comments on the proposed document.

Posting
This project was posted for a 60-day public comment period from November 15, 2024 through January
15, 2025.
WECC distributed the notice for the posting on November 15, 2024. The DT asked stakeholders to
provide feedback on the proposed document through a standardized electronic template. 22 comments
were received during the 60-day posting period.

Location of Comments
All comments received on the project can be viewed in their original format on the WECC-0142:
Request to Retire BAL-002-WECC-3, Contingency Reserve project page under the “Submit and Review
Comments” accordion.

Changes in Response to Comment
Clarifying changes have been made to the white paper. These changes did not affect the substance or
change the rationale that the drafting team put forth for the comment period. Besides grammar
updates, some changes made to the white paper are:
•

In the Executive Summary Section
o
o

Clarifying that BAL-002-WECC has required most but not all WECC entities to hold
more reserves.
Changing “reserves” in paragraph 4 to “the greater of, either the amount of Contingency
Reserve equal to the loss of the most severe single contingency or the amount of
Contingency reserve equal to the sum of” to be clearer.

•

o

Other minor wording changes.

Introduction
155 North 400 West | Suite 200 | Salt Lake City, Utah 84103
www.wecc.org

<Public>

WECC-0142: Request to Retire BAL-002-WECC-3, Contingency Reserve Response to
Comments, Posting 1
•
•

o

Minor wording changes.

o

Updating dates to 2025 and clarifying wording changes.

o

Removed a subjective phrase about cost from two sentences.

Procedural History
Reliability will be maintained

Minority View
During the 60-day comment period no minority view was presented.

Effective Date
TBD

Action Plan
The DT has voted at their 1/21/2025 meeting to request approval for Ballot from the WSC.

Contacts and Appeals
If you feel your comment has been omitted or overlooked, please contact Donovan Crane, Senior
Engineer, at (385) 408-9296. In addition, there is a WECC Reliability Standards appeals process.
Commenter

Organization

1

Kevin Conway

Western Power Pool

2

Steven Rueckert

WECC

3

Rebecca Zahler

PUD No. 1 of Chelan County

4

Adrian Andreoiu

BC Hydro

5

Lindsay Wickizer

Pacificorp

6

Holly Mitchell

Northwestern Energy

7

Jennie Wike

Tacoma Power

8

Michael Jang

Seattle City Light

9

ChaRee DiFabio

Western Power Pool

10

Anna Lavik

Puget Sound Energy

11

Marie Anderson

GCPUD

12

Alan Wahlstrom

Southwest Power Pool

13

Dwanique Spiller

NV Energy

14

Steven Ashbaker

Western Electricity Coordinating Council

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WECC-0142: Request to Retire BAL-002-WECC-3, Contingency Reserve Response to
Comments, Posting 1
Commenter

Organization

15

Tim Kelly

SMUD, BANC

16

Cain Braveheart

Bonneville Power Administration

17

Diana Torres

Imperial Irrigation District

18

Mike Pfeister

SRP

19

Ben Hammer

Western Area Power Administration - Rocky
Mountain Region (NCR05464), Western Area
Power Administration -Desert Southwest Region
(NCR05461), Western Area Power Administration
– Upper Great Plains Region (NCR05467)

20

Pablo Onate

El Paso Electric

21

Robert Follini

Avista Corporation

22

Brooke Jockin

Portland General Electric (PGE)

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WECC-0142: Request to Retire BAL-002-WECC-3, Contingency Reserve Response to
Comments, Posting 1

Index to Questions, Comments, and Responses
Question

1. Do you agree with the Drafting Team's request for the Standard to be retired? Yes/No
with a narrative explanation.
2. Do you agree with the Drafting Team's rationale for requesting the retirement of the
Standard? Yes/no with a narrative explanation
3. Do you have any other rationale that the drafting team may not have thought of or
included in this document? Yes/No with a narrative explanation

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WECC-0142: Request to Retire BAL-002-WECC-3, Contingency Reserve Response to
Comments, Posting 1

1. Do you agree with the Drafting Team's request for the Standard to be retired? Yes/No with
a narrative explanation.
Summary Consideration: See summary in the preamble of this document.
Commenter

Comment

Kevin Conway

Yes, the Western Power Pool supports the retirement of
BAL-002-WECC-3

Response

The Drafting Team appreciates your comments and input in this process.
Commenter

Comment

Rebecca Zahler

Yes, CHPD concurs with the Drafting Team’s request to
retire the BAL-002-WECC Standard. We support the
rationale outlined in the WECC-0142 Attachment A SAR
and the WECC-0142 BAL-002-WECC-3 White Paper.

Response

The Drafting Team appreciates your comments and input in this process.
Commenter

Comment

Adrian Andreoiu

Yes

Response

The Drafting Team appreciates your comments and input in this process.
Commenter

Comment

Lindsay Wickizer

Yes

Response

The Drafting Team appreciates your comments and input in this process.
Commenter

Comment

Holly Mitchell

Yes. The retirement of this standard is long overdue. This
retirement will enable WECC to be in line with the
continent-wide NERC BAL-002-3 as the industry rapidly
evolves to integrate IBRs and other alternative energy
sources. The retirement will also enhance reliable
operations by removing unnecessarily restrictive practices.

Response

The Drafting Team appreciates your comments and input in this process.
Commenter

Comment

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WECC-0142: Request to Retire BAL-002-WECC-3, Contingency Reserve Response to
Comments, Posting 1
Jennie Wike`

Yes

Response

The Drafting Team appreciates your comments and input in this process.
Commenter

Comment

Michael Jang

Yes, SCL is in agreement and full support with the Drafting
Team's request for the Standard to be retired. The
retirement of the WECC specific Reliability Standard does
not diminish or lessen the ability, intent and actions that
are taken during events the standard was initially created
to address.

Response

The Drafting Team appreciates your comments and input in this process.
Commenter

Comment

ChaRee DiFabio

Yes. In review of the NWPP RSG Data, the group holds
excess contingency reserve, at least two to three times the
MSSC, that its Participants could utilize to maintain other
operational needs, such as supporting the variable
resources and frequency response. In addition, as already
noted, it has economic impacts to these participants since
there are associated costs for holding back the Contingency
Reserve that could be used elsewhere to maintain
reliability. Last, the timing requirement from 60 minutes to
90 minutes does allow a more practical restoration period
to recover from the event and restore contingency reserve,
which should decrease the numbers and level of a potential
EEA3 since the entity will have time to assess more rational
restoration actions.

Response

The Drafting Team appreciates your comments and input in this process.
Commenter

Comment

Anna Lavik

Yes, PSE agrees that retirement would improve reliability
and free up available generation.

Response

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WECC-0142: Request to Retire BAL-002-WECC-3, Contingency Reserve Response to
Comments, Posting 1
The Drafting Team appreciates your comments and input in this process.
Commenter

Comment

Marie Anderson

Yes

Response

The Drafting Team appreciates your comments and input in this process.
Commenter

Comment

Alan Wahlstrom

Yes, the western interconnect is held at a higher standard
than the other Interconnects, It is unfair and places an
additional burden on operating resources as compared to
the other Interconnects.

Response

The Drafting Team appreciates your comments and input in this process.
Commenter

Comment

Dwanique Spiller

1. Yes, NV Energy agrees with the Drafting Team’s request
and that it provides operational efficiency, maintains
reliability, simplifies compliance, facilitates better
integration of IBRs, and provides economic benefits.

Response

The Drafting Team appreciates your comments and input in this process.
Commenter

Comment

Steven Ashbaker

Yes, I agree with the Drafting Teams request for the
Standard to be retired. Retirement of this standard would
free up excess reserves being held above the MSSC
requirements to serve system demand, without reducing
reliability in the WI. This additional available capacity
would be better used to address the issues associated with
IBR integration and variable generation.

Response

The Drafting Team appreciates your comments and input in this process. Your suggestions have
been taken into account in the revisions that have been made to the white paper.

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WECC-0142: Request to Retire BAL-002-WECC-3, Contingency Reserve Response to
Comments, Posting 1
Commenter

Comment

Tim Kelley

Yes. SMUD and BANC agree with the Drafting Team that
holding Contingency Reserves at a level of 3% load plus
3% generation is not technically supported and is more
than what is needed for bulk power system reliability. We
recognize that BAL-002-WECC-3 may provide additional
reliability for the large system events, such as double Palo
Verde unit tripping or Northwest RAS generation tripping,
which has occurred in the past. The Drafting Team should
consider adding some analysis in the white paper showing
that the reliability risks associated with these big system
events could still be adequately addressed with the
retirement of BAL-002-WECC-3. In addition, BAL-002WECC-3 Requirement R3 requires each sink BA and each
sink RSG to carry additional Contingency Reserves for
non-firm purchases of Contingency Reserves, and BAL002-WECC-3 Requirement R4 requires each source BA and
each sink RSG to carry additional Contingency Reserves
for firm sales of Contingency Reserves. We recommend
that the Drafting Team add some rationale in the white
paper for the retirement of these two requirements.

Response

The Drafting Team appreciates your comments and input in this process. Your suggestions have
been taken into account in the revisions that have been made to the white paper.
Commenter

Comment

Cain Braveheart

Yes. Bonneville Power Administration (BPA) believes the
current standard requires WECC entities to hold more
contingency reserves than is necessary and allows only 60
minutes to fully recover from an event. With the number of
variable generation resources coming online, the capacity
being unused by holding too much for contingency reserve
can be better allocated to ensure reliability of the
interconnection and to help balance the variable energy
resources. BPA believes the timing required by the markets
causes issues when trying to replenish reserves in the 60

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WECC-0142: Request to Retire BAL-002-WECC-3, Contingency Reserve Response to
Comments, Posting 1
minutes allocated. The 105 minutes allotted in BAL-002-3
(90 minutes after the Contingency Event Recovery Period)
is better suited for operations in a market environment.
Response

The Drafting Team appreciates your comments and input in this process.
Commenter

Comment

Diana Torres

Yes, As IID is a participant in the NWPP Reserve Sharing
Group, those Contingency Reserves must always be met
and held for use. As part of the RSG our reliability will not
be compromised. Communication between the RSG and
the BA have remained strong and will correspond and
respect the BAL-002-3 NERC standard that will take the
place of BAL-002-WECC-3 standard.

Response

The Drafting Team appreciates your comments and input in this process.
Commenter

Comment

Mike Pfeister

Yes, SRP does agree with the Drafting Team's request for
BAL-002-WECC-3 to be retired. NERC BAL-002-3 has a
proven history of meeting the needs of each
interconnection. The requirements in BAL-002-WECC-3
have not been found to be necessary in their history in the
Western Interconnection. With more variable resources in
the interconnection it makes sense to maximize the use of
freed up capacity, with the retirement of BAL-002-WECC3, to be used for regulation and capacity needs.

Response

The Drafting Team appreciates your comments and input in this process.
Commenter

Comment

Ben Hammer

Yes, Western Area Power Administration (WAPA)
enthusiastically supports the retirement of the BAL-002WECC-3 standard. WAPA operates three Balancing
Authorities (WALC, WACM, & WAUW) in the WECC

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WECC-0142: Request to Retire BAL-002-WECC-3, Contingency Reserve Response to
Comments, Posting 1
footprint. Each of our BAs also participate in the Northwest
Power Pool reserve sharing group. This participation has
allowed us to reduce our Contingency Reserve obligation
while maintaining reliability. All three BAs also participate
in organized imbalance markets. Operating our BAs and
meeting all the NERC reliability standards efficiently and
economically has become increasingly more difficult over
the last few years. We have a finite amount of capacity on
our federal hydro resources to balance our loads and
resources, maintain reliability, and satisfy our statutory
delivery obligations. This constraint has been negatively
impacted by the prolonged drought in the West and the
increase of Solar and Wind resources that have
interconnected to our systems. By retiring the more
stringent WECC standard, WAPA would realize a
significant reduction to the amount of capacity we would
have to commit for Contingency Reserves and would free
up this capacity to manage the variability of existing and
future variable renewable resources. Additionally, WAPA
supports extending the time requirement for restoring
Contingency Reserves after an event from 60 minutes to
105 minutes. This approach makes more operational and
commercial sense. Western market practices have made the
restoration of Contingency Reserves more challenging and
introduced more economic and operational risks. WAPA is
concerned with maintaining a standard that is not proven,
not evidence-based, and inconsistent with the rest of the
continent.
Response

The Drafting Team appreciates your comments and input in this process. Your suggestions have
been taken into account in the revisions that have been made to the white paper.
Commenter

Comment

Pablo Oñate

Yes. Historical background and technical rationale prompt
merit for standard retirement.

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WECC-0142: Request to Retire BAL-002-WECC-3, Contingency Reserve Response to
Comments, Posting 1
Response

The Drafting Team appreciates your comments and input in this process.
Commenter

Comment

Robert Follini

YES. The request to retire BAL-002-WECC-3 is justified and
needed for the Western Interconnection. The simple facts
clearly articulated in the White Paper that system reliability
is not impacted negatively by this change, and is likely
enhanced, while ensuring better use of existing generating
resources, both variable and base, should be clear enough
justification to retire BAL-002-WECC-3.

Response

The Drafting Team appreciates your comments and input in this process.
Commenter

Comment

Brooke Jockin

Yes.

Response

The Drafting Team appreciates your comments and input in this process.

11

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WECC-0142: Request to Retire BAL-002-WECC-3, Contingency Reserve Response to
Comments, Posting 1

2. Do you agree with the Drafting Team's rationale for requesting the retirement of the
Standard? Yes/no with a narrative explanation
Summary Consideration: See summary in the preamble of this document.
Commenter

Comment

Kevin Conway

Yes, the Western Power Pool supports the Drafting Team's
rational for requesting retirement of BAL-002-WECC-3

Response

The Drafting Team appreciates your comments and input in this process.
Commenter

Comment

Rebecca Zahler

Yes, CHPD concurs with the Drafting Team’s rationale for
requesting retirement of the BAL-002-WECC Standard. We
support the rationale outlined in the WECC-0142
Attachment A SAR and the WECC-0142 BAL-002-WECC-3
White Paper.

Response

The Drafting Team appreciates your comments and input in this process.
Commenter

Comment

Adrian Andreoiu

Yes

Response

The Drafting Team appreciates your comments and input in this process.
Commenter

Comment

Lindsay Wickizer

Yes

Response

The Drafting Team appreciates your comments and input in this process.
Commenter

Comment

Holly Mitchell

Yes. The requirements of NERC BAL-002-3 are sufficient to
maintain grid reliability for Balancing Contingency Events,
the 60-minute recovery timeframe in BAL-002-WECC-3 is
not consistent with the current market landscape and

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WECC-0142: Request to Retire BAL-002-WECC-3, Contingency Reserve Response to
Comments, Posting 1
exposes entities to greater risk for minimal reliability
benefit
Response

The Drafting Team appreciates your comments and input in this process.
Commenter

Comment

Jennie Wike`

Yes

Response

The Drafting Team appreciates your comments and input in this process.
Commenter

Comment

Michael Jang

Yes, SCL is in agreement Drafting Team's rationale for
requesting the retirement of the Standard. SCL strongly
agrees wiht the rationale that the existing BAL-002-WECC3, Contingency Reserve requirement does not enhance
reliability of the interconnection. In fact, it decreases
reliability of the interconnection. For SCL, being a heavily
sourced hydro generation facility Balancing Authority, the
current BAL-002-WECC-3, Contingency Reserve
requirement results in a major negative operational impact
due to our limited (cfs inflow & safe reservoir levels) fuel
supply and no meaningful reliability benefit for
maintaining compliance for it.

Response

The Drafting Team appreciates your comments and input in this process.
Commenter

Comment

ChaRee DiFabio

Yes. The drafting team has been able to utilize historical
information and data in support of this rationale.

Response

The Drafting Team appreciates your comments and input in this process.
Commenter

Comment

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WECC-0142: Request to Retire BAL-002-WECC-3, Contingency Reserve Response to
Comments, Posting 1
Anna Lavik

Yes, PSE only sees benefits of the retirement of BAL-002WECC-3 and agrees with the rational provided by the
Drafting team.

Response

The Drafting Team appreciates your comments and input in this process.
Commenter

Comment

Marie Anderson

Yes

Response

The Drafting Team appreciates your comments and input in this process.
Commenter

Comment

Alan Wahlstrom

Yes, having operating reserves to cover the largest
contingency makes sense because you are recovering what
is lost but the 3% rule there is no technical justification. Is
3% right amount? should it be 2% or 4%. Does this
requirement make sense today? This is not for the team but
maybe for WECC, could a study be developed with
different IBR penetration to verify reliable operation with
the 60 min recovery and the 3% rule reserve.

Response

The Drafting Team appreciates your comments and input in this process.
Commenter

Comment

Dwanique Spiller

2. Yes, NV Energy agrees with the rationale that retiring
the Standard provides alignment with the rest of the
continent and FERC Order 901 and frees up resources to be
used more effectively against ever increasing load
demands and installation of variable generation.

Response

The Drafting Team appreciates your comments and input in this process.
Commenter

Comment

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WECC-0142: Request to Retire BAL-002-WECC-3, Contingency Reserve Response to
Comments, Posting 1
Steven Ashbaker

Yes, I agree with the Drafting Team's rational for
requesting retirement. See response to Q1.

Response

The Drafting Team appreciates your comments and input in this process. Your suggestions have
been taken into account in the revisions that have been made to the white paper.
Commenter

Comment

Tim Kelley

Yes. SMUD and BANC agree with the Drafting Team’s
rationale for requesting the retirement of the Standard.
However, the rationale could be bolstered if the Drafting
Team added some analysis in the White Paper showing
that the reliability risks associated with the big system
events could still be adequately addressed with the
retirement of BAL-002-WECC-3 and add some rationale to
address the retirement of Requirements R3 and R4.

Response

The Drafting Team appreciates your comments and input in this process. Your suggestions have
been taken into account in the revisions that have been made to the white paper.
Commenter

Comment

Cain Braveheart

Yes. See BPA’s response to question 1.

Response

The Drafting Team appreciates your comments and input in this process.
Commenter

Comment

Diana Torres

Yes, After reviewing the drafting team’s paper IID is in
agreement with the request for retirement. The rationale
clearly states the differences of the two standards and there
are concrete explanations as to the requirements for BAL002-3 standard to be followed. IID will abide and
implement as needed.

Response

The Drafting Team Appreciates your comments and input in this process.

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WECC-0142: Request to Retire BAL-002-WECC-3, Contingency Reserve Response to
Comments, Posting 1
Commenter

Comment

Mike Pfeister

Yes, the Drafting Team's rationale is sound. We have
history in the Western Interconnection and other
interconnections to support this rationale.

Response

The Drafting Team appreciates your comments and input in this process.
Commenter

Comment

Ben Hammer

Yes, see response to question #1

Response

The Drafting Team appreciates your comments and input in this process. Your suggestions have
been taken into account in the revisions that have been made to the white paper.
Commenter

Comment

Pablo Oñate

Yes. See response to #1

Response

The Drafting Team appreciates your comments and input in this process.
Commenter

Comment

Brooke Jockin

Yes.

Response

The Drafting Team appreciates your comments and input in this process.

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WECC-0142: Request to Retire BAL-002-WECC-3, Contingency Reserve Response to
Comments, Posting 1

3. Do you have any other rationale that the drafting team may not have thought of or
included in this document? Yes/No with a narrative explanation
Summary Consideration: See summary in the preamble of this document.
Commenter

Comment

Kevin Conway

The Western Power Pool has no additional rationale that
the Drafting Team should consider.

Response

The Drafting Team appreciates your comments and input in this process.
Commenter

Comment

Rebecca Zahler

Yes, CHPD concurs with the Drafting Team’s rationale for
requesting retirement of the BAL-002-WECC Standard. We
support the rationale outlined in the WECC-0142
Attachment A SAR and the WECC-0142 BAL-002-WECC-3
White Paper.

Response

The Drafting Team appreciates your comments and input in this process.
Commenter

Comment

Steve Rueckert

I have several clarifying comments:
In the Executive Summary it states "BAL-002-WECC has
always required holding more reserves..." This is not true.
BAL-002-WECC generally requires more reserves because
it requires the "greater of 3% Load and 3% generation or
MSSC" but a BA or RSG may at times have MSSC as the
greater of, so that would be the same as the NERC
Standard.
There is a sentence that says the applicable entity must
hold reserves based on three percent of load and three
percent of generation. This is not true. BAL-002-WECC
requires "the greater of" three percent of load and three
percent of generation or MSSC.

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WECC-0142: Request to Retire BAL-002-WECC-3, Contingency Reserve Response to
Comments, Posting 1
On page 17, directly below the CRO-MSSC graph, the title
says "the shortened execution time of BAL-003-WECC-3..."
It should be BAL-002-WECC-3.
On page 19 it states that "Every energy customer in the
absorbs this excess cost." Should it state "Every energy
customer int the West absorbs this excess cost?"
On page 19 it again refers to BAL-003-WECC-3. It should
be BAL-002-WECC-3.
On page 23, the last sentence of the first paragraph doesn't
seem to make sense. The ending says "declare an EEA any
time the reserves need restored within 60 minutes of the
event." Seems like a word may be missing.
On page 24 towards the end of the last paragraph reference
is made to an Emergency Alert 3. Should this say and
Energy Emergency Alert 3?
Response

The Drafting Team appreciates your comments and input in this process. Your suggestions have
been taken into account in the revisions that have been made to the white paper.
Commenter

Comment

Lindsay Wickizer

No

Response

The Drafting Team appreciates your comments and input in this process.
Commenter

Comment

Holly Mitchell

No additional rationale.

Response

The Drafting Team appreciates your comments and input in this process.
Commenter

Comment

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WECC-0142: Request to Retire BAL-002-WECC-3, Contingency Reserve Response to
Comments, Posting 1
Jennie Wike`

No, Tacoma Power concurs with the rationale proposed by
the drafting team and is supportive of this effort to retire
BAL-002-WECC-3 entirely.

Response

The Drafting Team appreciates your comments and input in this process.
Commenter

Comment

Michael Jang

No. SCL does not have other rationale that the drafting
team may not have thought of or included in the
document.

Response

The Drafting Team appreciates your comments and input in this process.
Commenter

Comment

ChaRee DiFabio

No

Response

The Drafting Team appreciates your comments and input in this process.
Commenter

Comment

Anna Lavik

PSE does not have any additional rational that was
overlooked by the drafting team.

Response

The Drafting Team appreciates your comments and input in this process.
Commenter

Comment

Marie Anderson

Yes

Response

The Drafting Team appreciates your comments and input in this process.
Commenter

Comment

Alan Wahlstrom

Yes More organizations are becoming BA's in the west with
many of these organizations presently having a BA
footprint in the Eastern Interconnect. The BA operation in

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WECC-0142: Request to Retire BAL-002-WECC-3, Contingency Reserve Response to
Comments, Posting 1
the west must be different than the east, causing the BA to
have different sets of operating criteria. If the NERC BAL-2
is excepted for the west it would provide continuity and
simplifying the overall operation of the BA.
Response

The Drafting Team appreciates your comments and input in this process.
Commenter

Comment

Dwanique Spiller

No.

Response

The Drafting Team appreciates your comments and input in this process.
Commenter

Comment

Steven Ashbaker

Provided Redline comments and proposed edits to
Donovan Crane, Staff and Kevin Conway, DT Chair.

Response

The Drafting Team appreciates your comments and input in this process. Your suggestions have
been taken into account in the revisions that have been made to the white paper.
Commenter

Comment

Tim Kelley

No.

Response

The Drafting Team appreciates your comments and input in this process. Your suggestions have
been taken into account in the revisions that have been made to the white paper.
Commenter

Comment

Cain Braveheart

No. BPA believes the rationale provided by the drafting
team offers a clear explanation and technical justification
for the full retirement of BAL-002-WECC-3.

Response

The Drafting Team appreciates your comments and input in this process.
Commenter

Comment

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WECC-0142: Request to Retire BAL-002-WECC-3, Contingency Reserve Response to
Comments, Posting 1
Diana Torres

Yes, the IID has reviewed and respects the rationale of the
Drafting Team on the request to retire BAL-002-WECC-3.

Response

The Drafting Team appreciates your comments and input in this process.
Commenter

Comment

Mike Pfeister

SRP has no other rationale to add to the Drafting Team's
work.

Response

The Drafting Team appreciates your comments and input in this process.
Commenter

Comment

Ben Hammer

No

Response

The Drafting Team appreciates your comments and input in this process. Your suggestions have
been taken into account in the revisions that have been made to the white paper.
Commenter

Comment

Pablo Oñate

No. The whitepaper represents ideas well and EPE
subscribes to its rationale.

Response

The Drafting Team appreciates your comments and input in this process.

21

NERC Posting – Record of Development
BAL-002-WECC-3
(1) Clean
(2) White Paper
(3) Project Roadmap
(4) Announcement
(5) Unofficial Comment Form (Word)
(6) Comments Received

BAL-002-WECC-3—Contingency Reserve

A. Introduction
1.

Title:

Contingency Reserve

2.

Number:

BAL-002-WECC-3

3.

Purpose:

To specify the quantity and types of Contingency Reserve required to
ensure reliability under normal and abnormal conditions.

4.

Applicability:
4.1. Functional Entities:
4.1.1 Balancing Authority
4.1.1.1

The Balancing Authority is the responsible entity unless the
Balancing Authority is a member of a Reserve Sharing Group, in
which case, the Reserve Sharing Group becomes the responsible
entity.

4.1.2 Reserve Sharing Group

5.

4.1.2.1

The Reserve Sharing Group when comprised of a Source Balancing
Authority becomes the source Reserve Sharing Group.

4.1.2.2

The Reserve Sharing Group when comprised of a Sink Balancing
Authority becomes the sink Reserve Sharing Group.

Effective Date:

Immediately upon receipt of regulatory approval.

B. Requirements and Measures
R1.

Each Balancing Authority and each Reserve Sharing Group shall maintain a minimum
amount of Contingency Reserve, except within the first sixty minutes following an
event requiring the activation of Contingency Reserve, that is: [Violation Risk Factor:
High] [Time Horizon: Real-time operations]
1.1. The greater of either:
•

The amount of Contingency Reserve equal to the loss of the most severe
single contingency;

•

The amount of Contingency Reserve equal to the sum of three percent of
hourly integrated Load plus three percent of hourly integrated generation.

1.2. Composed of any combination of the reserve types specified below:
•

Operating Reserve—Spinning

•

Operating Reserve—Supplemental

•

Interchange Transactions designated by the Source Balancing Authority as
Operating Reserve—Supplemental

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BAL-002-WECC-3—Contingency Reserve

•

Reserve held by other entities by agreement that is deliverable on Firm
Transmission Service

•

A resource, other than generation or load, that can provide energy or reduce
energy consumption

•

Load, including demand response resources, Demand-Side Management
resources, Direct Control Load Management, Interruptible Load or
Interruptible Demand, or any other Load made available for curtailment by
the Balancing Authority or the Reserve Sharing Group via contract or
agreement.

•

All other load, not identified above, once the Reliability Coordinator has
declared an energy emergency alert signifying that firm load interruption is
imminent or in progress.

1.3. Based on real-time hourly load and generating energy values averaged over each
Clock Hour (excluding Qualifying Facilities covered in 18 C.F.R.§ 292.101, as
addressed in FERC Order 464).
1.4. An amount of capacity from a resource that is deployable within ten minutes.
M1. Each Balancing Authority and each Reserve Sharing Group will have documentation
demonstrating its Contingency Reserve was maintained, except within the first sixty
minutes following an event requiring the activation of Contingency Reserve.
Part 1.1
Each Balancing Authority and each Reserve Sharing Group will have dated
documentation that demonstrates its Contingency Reserve was maintained in
accordance with the amounts identified in Requirement R1, Part 1.1, except within the
first sixty minutes following an event requiring the activation of Contingency Reserve.
Attachment A is a practical illustration showing how the generation amount may be
calculated under Requirement R1.
•

•

Where Dynamic Schedules are used as part of the generation amount upon
which Contingency Reserve is predicated, additional evidence of compliance
with Requirement R1, Part 1.1 may include, but is not limited to,
documentation showing a reciprocal acknowledgement as to which entity is
carrying the reserves. This transfer may be all or some portion of the physical
generator and is not limited to the entire physical capability of the generator.
Where Pseudo-Ties are used as part of the generation amount upon which
Contingency Reserve is predicated, additional evidence of compliance with
Requirement R1, Part 1.1, may include, but is not limited to, documentation
accounting for the transfers included in the Pseudo-Ties.

Part 1.2
Each Balancing Authority and each Reserve Sharing Group will have dated
documentation that demonstrates compliance with Requirement R1, Part 1.2.
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BAL-002-WECC-3—Contingency Reserve

Evidence may include, but is not limited to, documentation that reserves were
comprised of the types listed in Requirement R1, Part 1.2 for purposes of meeting the
Contingency Reserve obligation of Requirement R1. Additionally, for purposes of the
last bullet of Requirement R1, Part 1.2, evidence of compliance may include, but is not
limited to, documentation that the reliability coordinator had issued an energy
emergency alert, indicating that firm Load interruption was imminent or was in
progress.
Part 1.3
Each Balancing Authority and each Reserve Sharing Group will have dated
documentation that demonstrates compliance with Requirement R1, Part 1.3.
Evidence of compliance with Requirement R1, Part 1.3 may include, but is not limited
to, documentation that Contingency Reserve amounts are based upon load and
generating data averaged over each Clock Hour and excludes Qualifying Facilities
covered in 18 C.F.R.§ 292.101, as addressed in FERC Order 464.
Part 1.4
Evidence of compliance with Requirement R1, Part 1.4 may include, but is not limited
to, documentation that the reserves maintained to comply with Requirement R1, Part
1.4 are fully deployable within ten minutes.
R2. Reserved.
M2. Reserved.
R3.

Each Sink Balancing Authority and each sink Reserve Sharing Group shall maintain an
amount of Operating Reserve, in addition to the minimum Contingency Reserve in
Requirement R1, equal to the amount of Operating Reserve–Supplemental for any
Interchange Transaction designated as part of the Source Balancing Authority’s
Operating Reserve–Supplemental or source Reserve Sharing Group’s Operating
Reserve–Supplemental, except within the first sixty minutes following an event
requiring the activation of Contingency Reserve. [Violation Risk Factor: High] [Time
Horizon: Real-time operations]

M3. Each Sink Balancing Authority and each sink Reserve Sharing Group will have dated
documentation demonstrating it maintained an amount of Operating Reserve, in
addition to the Contingency Reserve identified in Requirement R1, equal to the
amount of Operating Reserve–Supplemental for any Interchange Transaction
designated as part of the Source Balancing Authority’s Operating Reserve–
Supplemental or source Reserve Sharing Group’s Operating Reserve–Supplemental,
for the entire period of the transaction, except within the first sixty minutes following
an event requiring the activation of Contingency Reserves, in accordance with
Requirement 3.
R4.

Each Source Balancing Authority and each source Reserve Sharing Group shall
maintain an amount of Operating Reserve, in addition to the minimum Contingency
Reserve amounts identified in Requirement R1, equal to the amount and type of

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BAL-002-WECC-3—Contingency Reserve

Operating Reserves for any Operating Reserve transactions for which it is the Source
Balancing Authority or source Reserve Sharing Group. [Violation Risk Factor: High]
[Time Horizon: Real-time operations]
M4. Each Source Balancing Authority and each source Reserve Sharing Group will have
dated documentation that demonstrates it maintained an amount of additional
Operating Reserves identified in Requirement R1, greater than or equal to the amount
and type of that identified in Requirement 4, for the entire period of the transaction.

C. Compliance
1.

Compliance Monitoring Process
1.1. Compliance Enforcement Authority:
For entities that do not work for the Regional Entity, the Regional Entity shall
serve as the Compliance Enforcement Authority.
For Reliability Coordinators and other functional entities that work for their
Regional Entity, the ERO or a Regional Entity approved by the ERO and FERC or
other applicable governmental authorities shall serve as the Compliance
Enforcement Authority.
For responsible entities that are also Regional Entities, the ERO or a Regional
Entity approved by the ERO and FERC or other applicable governmental
authorities shall serve as the Compliance Enforcement Authority.
1.2. Compliance Monitoring and Assessment Processes:
Compliance Audit
Self-Certification
Spot-Checking
Compliance Investigation
Self-Reporting
Complaint
1.3.

Evidence Retention:
The following evidence retention periods identify the period of time an entity is
required to retain specific evidence to demonstrate compliance. For instances
where the evidence retention period specified below is shorter than the time
since the last audit, the Compliance Enforcement Authority may ask an entity to
provide other evidence to show that it was compliant for the full-time period
since the last audit.
Each Balancing Authority and each Reserve Sharing Group shall keep evidence
for Requirement R1 through R4 for three years plus calendar current.

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BAL-002-WECC-3—Contingency Reserve

1.4. Additional Compliance Information:
1.4.1 This Standard shall apply to each Balancing Authority and each Reserve
Sharing Group that has registered with WECC as provided in Part 1.4.2 of
Section C.
Each Balancing Authority identified in the registration with WECC as
provided in Part 1.4.2 of Section C shall be responsible for compliance with
this Standard through its participation in the Reserve Sharing Group and
not on an individual basis.
1.4.2 A Reserve Sharing Group may register as the Responsible Entity for
purposes of compliance with this Standard by providing written notice to
the WECC: 1) indicating that the Reserve Sharing Group is registering as the
Responsible Entity for purposes of compliance with this Standard, 2)
identifying each Balancing Authority that is a member of the Reserve
Sharing Group, and 3) identifying the person or organization that will serve
as agent on behalf of the Reserve Sharing Group for purposes of
communications and data submissions related to or required by this
Standard.
1.4.3 If an agent properly designated in accordance with Part 1.4.2 of Section C
identifies individual Balancing Authorities within the Reserve Sharing Group
responsible for noncompliance at the time of data submission, together
with the percentage of responsibility attributable to each identified
Balancing Authority, then, except as may otherwise be finally determined
through a duly conducted review or appeal of the initial finding of
noncompliance: 1) any penalties assessed for noncompliance by the
Reserve Sharing Group shall be allocated to the individual Balancing
Authorities identified in the applicable data submission in proportion to
their respective percentages of responsibility as specified in the data
submission, 2) each Balancing Authority shall be solely responsible for all
penalties allocated to it according to its percentage of responsibility as
provided in subsection 1) of this Part 1.4.3 of Section C, and 3) neither the
Reserve Sharing Group nor any member of the Reserve Sharing Group shall
be responsible for any portion of a penalty assessed against another
member of the Reserve Sharing Group in accordance with subsection 1) of
this Part 1.4.3 of Section C (even if the member of Reserve Sharing Group
against which the penalty is assessed is not subject to or otherwise fails to
pay its allocated share of the penalty).
1.4.4 If an agent properly designated in accordance with Part 1.4.2 of Section C
fails to identify individual Balancing Authorities within the Reserve Sharing
Group responsible for noncompliance at the time of data submission or
fails to specify percentages of responsibility attributable to each identified
Balancing Authority, any penalties for noncompliance shall be assessed
against the agent on behalf of the Reserve Sharing Group, and it shall be
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BAL-002-WECC-3—Contingency Reserve

the responsibility of the members of the Reserve Sharing Group to allocate
responsibility for such noncompliance.
1.4.5 Any Balancing Authority that is a member of a Reserve Sharing Group that
has failed to register as provided in Part 1.4.2 of Section C shall be subject
to this Standard on an individual basis.

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BAL-002-WECC-3—Contingency Reserve

Violation Severity Levels
Violation Severity Levels
R#

Lower VSL

Moderate VSL

High VSL

Severe VSL

R1.

The Balancing Authority or
the Reserve Sharing Group
that incurs one Clock Hour,
during a calendar month, in
which Contingency Reserve
is less than 100% but greater
than or equal to 90% of the
required Contingency
Reserve amount, with the
characteristics specified in
Requirement R1.

The Balancing Authority or
the Reserve Sharing Group
that incurs one Clock Hour,
during a calendar month, in
which Contingency Reserve
is less than 90% but greater
than or equal to 80% of the
required Contingency
Reserve amount, with the
characteristics specified in
Requirement R1.

The Balancing Authority or
the Reserve Sharing Group
that incurs one Clock Hour,
during a calendar month, in
which Contingency Reserve
is less than 80% but greater
than or equal to 70% of the
required Contingency
Reserve amount, with the
characteristics specified in
Requirement R1.

The Balancing Authority or
the Reserve Sharing Group
that incurs one Clock Hour,
during a calendar month, in
which Contingency Reserve
is less than 70% of the
required Contingency
Reserve amount, with the
characteristics specified in
Requirement R1.

R2.

Reserved.

R3.

The Balancing Authority or
the Reserve Sharing Group
that incurs one hour, during
a calendar month, in which
Contingency Reserve is less
than 100% but greater than
or equal to 90% of the
required Operating Reserve
amount specified in
Requirement R3.
The Balancing Authority or
the Reserve Sharing Group

The Balancing Authority or
the Reserve Sharing Group
that incurs one hour, during
a calendar month, in which
Contingency Reserve is less
than 90% but greater than or
equal to 80% of the required
Operating Reserve amount
specified in Requirement R3.

The Balancing Authority or
the Reserve Sharing Group
that incurs one hour, during
a calendar month, in which
Contingency Reserve is less
than 80% but greater than
or equal to 70% of the
required Operating Reserve
amount specified in
Requirement R3.
The Balancing Authority or
the Reserve Sharing Group

The Balancing Authority or
the Reserve Sharing Group
that incurs one hour, during
a calendar month, in which
Contingency Reserve is less
than 70% of the required
Operating Reserve amount
specified in Requirement R3.

R4.

The Balancing Authority or
the Reserve Sharing Group

The Balancing Authority or
the Reserve Sharing Group

Page 7 of 13

BAL-002-WECC-3—Contingency Reserve

that incurs one hour, during
a calendar month, in which
Contingency Reserve
Operating Reserve is less
than 100% but greater than
or equal to 90% of the
required Operating Reserve
amount specified in
Requirement R4.

that incurs one hour, during
a calendar month, in which
Contingency Reserve
Operating Reserve is less
than 90% but greater than or
equal to 80% of the required
Operating Reserve amount
specified in Requirement R4.

that incurs one hour, during
a calendar month, in which
Contingency Reserve
Operating Reserve is less
than 80% but greater than
or equal to 70% of the
required Operating Reserve
amount specified in
Requirement R4.

that incurs one hour, during
a calendar month, in which
Contingency Reserve
Operating Reserve is less
than 70% of the required
Operating Reserve amount
specified in Requirement R4.

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BAL-002-WECC-3—Contingency Reserve

D. Regional Variances
None.

E. Interpretations
None.

F. Associated Documents
None.

Page 9 of 13

BAL-002-WECC-3—Contingency Reserve

Version History
Version

Date

1

October 29, 2008

1

October 21, 2010

2

November 7, 2012

2

November 21, 2013

2a

December 1, 2015

Approved by WECC Board
of Directors

2a

January 24, 2017

FERC approved

3

August 15, 2019

Action

Change Tracking

Adopted by NERC Board
of Trustees
Order issued remanding
BAL-002-WECC-1
Adopted by NERC Board
of Trustees
FERC Order issued
approving BAL-002WECC-2. (Order becomes
effective 1/28/14.)

Adopted by the NERC
Board of Trustees

3

April 15, 2021

FERC approved

3

June 28, 2021

Effective Date of
Standard

Clarified resources
available for use in
Requirement R2
The Interpretation
provides clarification
regarding the types of
resources that may be
used to satisfy
Contingency Reserve.
The Interpretation was
removed. Requirement
R2 was deleted.
Template and
formatting were
updated. Syntax and
verb tense in Guideline
section were
corrected.
Docket(s): RM19-20-000
Description: Order No.
876: Final Rule re WECC
Regional Reliability
Standard BAL-002-WECC3 (Contingency Reserve)
under RM19-20.

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BAL-002-WECC-3—Contingency Reserve

Standard Attachments
Attachment A
Attachment A is illustrative only; it is not a requirement. Requirement R1 calls for an amount of
Contingency Reserve to be maintained, predicated on an amount of generation and load
required in Requirement R1, Part 1.1., specifically:
“1.1

The greater of either:
•

The amount of Contingency Reserve equal to the loss of the most severe
single contingency;

•

The amount of Contingency Reserve equal to the sum of three percent of
hourly integrated Load plus three percent of hourly integrated generation.”

Attachment A illustrates one possible way to account for and calculate the amount of
generation upon which the Contingency Reserve amount is predicated.
Below is a practical illustration showing how the generation amount may be calculated under
Requirement R1 for Balancing Authorities (BA) and Reserve Sharing Groups (RSG).
BA1 / RSG 1

Generation

Part of Generator

Generator 1
Generator 2
Generator 3 (Pseudo-Tied out to BA2)
Generator 4 QF (has backup contract)
Generator 5 QF in EMS
Generator 6

300 MWs online
200 MWs online
100 MWs online
10 MWs online
10 MWs online
0 MWs online

Yes
Yes
No
No
Yes
Yes

Dynamic Schedule to BA2 from BA11

(50 MWs)

Generation
BA generation (EMS)
Generation to use Under BAL-002-WECC-1

620 MWs
510 MWs
460 MWs**

(The sum of gen 1–6)
(The sum of gen 1, 2, and 5)
(The sum of gen 1, 2, and 5
minus Dynamic Schedule)

** Assumes BA1 and BA2 agree on Dynamic Schedule treatment. If no agreement, BA1 would
maintain reserves based on 510 MWs Generation.
BA2 / RSG2

Generation

Part of Generator

Generator 11
Generator 12
Generator 3 (Pseudo-Tied in from BA1)

100 MWs
100 MWs
100 MWs

Yes
Yes
Yes

Dynamic Schedule from BA1 to BA2

50 MWs

Yes

Generation
BA generation (EMS)

300 MWs
300 MWs

(The sum of gen 11, 12 and 3.)
(The sum of gen 11, 12 and 3)

1

Note: This Dynamic Schedule is not the same as the Generator 3 Pseudo-Tie.

Page 11 of 13

BAL-002-WECC-3—Contingency Reserve

Generation to use Under BAL-002-WECC-1

350 MWs**

(The sum of gen 11, 12 and 3
plus Dynamic Schedule)

** Assumes BA1 and BA2 agree on Dynamic Schedule treatment. If no agreement, BA1 would
have to maintain reserves based on 510MWs Generation and BA2 would determine its
generation to be 300 MWs.

Page 12 of 13

BAL-002-WECC-3—Contingency Reserve (Attachment C)—Supplemental Material

Guideline and Technical Basis
A Guidance Document addressing implementation of this standard was filed with Version 2.

Page 13 of 13

WECC-0142 BAL-002-WECC-3—Contingency Reserve—Request to Retire
Executive Summary
This document supports and requests full retirement of WECC Regional Reliability Standard (RRS)
BAL-002-WECC-3, Contingency Reserve.
In FERC Order No. 672, when considering approval of RRSs, FERC agreed to accept two kinds of
regional differences: (1) a regional difference that is more stringent than the continent-wide Reliability
Standard, including a regional difference that addresses matters that the continent-wide Reliability
Standard does not; and (2) an RRS that is necessitated by a physical difference in the Bulk-Power
System.1
Order 672 also provides authority to retire an RRS.
Since the start of BAL-002-WECC-3 and its predecessors (2007), the original standard and each
subsequent iteration have continued as more stringent than the continent-wide equivalent, NERC BAL002-X, Disturbance Control Standard. Among other things, WECC’s BAL-002-WECC has always
required most WECC entities to hold more reserves than the continent-wide equivalent. Specifically,
BAL-002-WECC-3, Requirement R1.1.1 requires the applicable entity to hold the greater of, either the
amount of Contingency Reserve equal to the loss of the most severe single contingency or the amount
of Contingency Reserve equal to the sum of 3% of hourly integrated load and 3% of hourly integrated
generation.
Though Requirement R1.1.1 was approved in BAL-002-WECC-1, that approval was predicated on
distributing burden and the availability of deliverability.2 There has never been a technical study
proving that holding reserves more than required under NERC BAL-002-X enhances the reliability of
the Western Interconnection.
By contrast, as variable generation is added to the Interconnection, there is increasing evidence that
holding excess reserves may be inhibiting reliability across the interconnection. FERC’s recent Order
901 echoes these concerns, addressing operational and performance concerns for variable resources.
Restated, within the Western Interconnection, applicable entities are holding more reserves than the
rest of the continent, even though there is no technical basis for doing so. In FERC Order 693, in which
NERC BAL-002-1 was first approved, at P341, FERC states:
341. We believe a continent-wide contingency reserves policy would assure [sic] that there are
adequate magnitude and frequency responsive contingency reserves in each Balancing

Order No. 672 at P 331. See also FERC Order 740, P 4 and P 23.
https://www.nerc.com/pa/Stand/Resources/Documents/FERC'S Criteria for Approving Reliability Standards fr
om Order 672.pdf
2 FERC Order 740, Remand.
1

2

WECC-0142 BAL-002-WECC-3—Contingency Reserve—Request to Retire
Authority. This will improve performance so that no Balancing Authority will be doing less than
its fair share.” (Emphasis added.)
By extension, retiring BAL-002-WECC-3 in favor of NERC BAL-002-3, ensures that no Balancing
Authority will be doing more than its fair share.
Further, requiring Balancing Authorities to hold that excess may be inhibiting the integration and use
of variable generation. As a result, BAL-002-WECC-3 creates a mandated scenario in which reserves are
used inefficiently and withheld from the marketplace.

3

WECC-0142 BAL-002-WECC-3—Contingency Reserve—Request to Retire

Table of Contents
Introduction .............................................................................................................................................................5
Standard of Review ................................................................................................................................................6
Procedural History..................................................................................................................................................7
Development History (Pre-1996 to 2024) ............................................................................................................8
Structural Overview of BAL-002-WECC-3 .......................................................................................................11
Purpose ...............................................................................................................................................................11
Applicability ......................................................................................................................................................11
Requirements .....................................................................................................................................................11
Requirement R1 .............................................................................................................................................11
Requirement R2 .............................................................................................................................................11
Requirement R3 .............................................................................................................................................12
Requirement R4 .............................................................................................................................................12
Reliability will be Maintained...........................................................................................................................13
Vital Public Interests will be Enhanced ..........................................................................................................18
Market Timing Issues .......................................................................................................................................18
Capacity Could be Better Utilized than Simply Holding Reserve .............................................................20
Conclusion .............................................................................................................................................................22

4

WECC-0142 BAL-002-WECC-3—Contingency Reserve—Request to Retire

Introduction
Per the Standard Authorization Request (SAR) for WECC-0142,3 this document explores the full
retirement of WECC RRS BAL-002-WECC-3, Contingency Reserve.
The following will show that, if the standard is retired, reliability will continue to be maintained
through NERC BAL-002-3, and may be enhanced as resources being held for contingency reserves may
be used more efficiently to support variable generation.
By retiring BAL-002-WECC-3 in favor of NERC BAL-002-3:
•

Dispatchable resources can be used to support variable generation, addressing issues raised by
FERC in Order 901.

•

A more efficient use of resources should negate any current negative impacts on the market,
thereby enhancing vital public interests.

As the Procedural History and Development History sections note, BAL-002-WECC-3 is an evolution of
pre-standards originating in the 1990s. Never during the estimated 30 years of its existence has there
been a technical justification for the values and procedures required in the standard. Rather, the stated
values and procedures are the result of generalized negotiations taking place between the parties.
Because these values and procedures are negotiated, the content of BAL-002-WECC-3 is the lowest
common denominator and does not meet the requirements of FERC Order 672.4
Because BAL-002-WECC-2a, Contingency Reserve, Request to Retire Requirement R2 provided the
technical support for retiring Requirement R2, arguments in that filing are not revisited here.5

See WECC-0142 BAL-002-WECC-3, Contingency Reserve, Request to Retire, home page, at the SAR accordion.
FERC Order 672, P329 and P330.
5 Approved by the NERC Board of Trustees on August 15, 2019, filed with FERC on September 9, 2019.
3
4

5

WECC-0142 BAL-002-WECC-3—Contingency Reserve—Request to Retire

Standard of Review
While the Commission may approve an RRS that is more stringent than a parallel continent-wide
standard, the Commission may also retire such a standard.6
“While a Regional Entity may propose regional Reliability Standards that address specific,
unique regional conditions and circumstances, such regional Reliability Standards can be retired if
those justifications are no longer relevant. Accordingly, the Commission may approve retirement of
a more stringent regional requirement “if the Regional Entity demonstrates that the continentwide Reliability Standard is sufficient to ensure the reliability of that region.”7 (Emphasis
added.)
In doing so, the Commission must give due weight to the technical expertise of a Regional Entity, like
WECC, that is organized on an interconnection-wide basis with respect to the regional differences
applicable to the Western Interconnection.
The technical qualifications of the subject matter experts compiling this paper are provided with this
filing, as presented and approved by the WECC Standards Committee (WSC).

The Commission approves regional differences proposed by Regional Entities, such as Regional Reliability
Standards and Variances, if the regional difference is just, reasonable, not unduly discriminatory or preferential,
and in the public interest. 16 U.S.C. § 824o(d)(2) and 18 C.F.R. § 39.5(a). (See also) Additionally, Commission
Order No. 672 requires further criteria for regional differences. A regional difference from a continent-wide
Reliability Standard must either be:
(1) more stringent than the continent-wide Reliability Standard, including a regional difference that addresses
matters that the continent-wide Reliability Standard does not; or is,
(2) necessitated by a physical difference in the Bulk-Power System.
7 Version One Regional Reliability Standard for Resource and Demand Balancing,
Order No. 740, 75 FR 65964 (Oct. 27, 2010), 133 FERC ¶ 61,063, P 30 (2010). See also: FERC, 18 CFR Part 40, Docket
No. RM19-20-000, WECC Regional Reliability Standard BAL-002-WECC-3 (Contingency Reserve), p.5
6

6

WECC-0142 BAL-002-WECC-3—Contingency Reserve—Request to Retire

Procedural History
In 1996, the Western Systems Coordinating Council (WSCC)8 adopted the WSCC Reliability Criteria,
Minimum Operating Reliability Criteria (MORC). The MORC prescribed levels of reserves that became
BAL-002-WECC-3, effective 2021.
In 1999, the MORC became the WECC Reliability Management System (RMS), a contract-based system
of accountability that pre-dated mandatory standards.
As the industry approached the onset of mandatory standards (2007) and memorialization of legacy
operating practices, the content of the RMS was adapted and approved as BAL-STD-002-0, Operating
Reserves (2007). That standard was an attempt to translate the substantive content of the RMS into the
sought-after NERC/FERC format of today’s reliability standards. The content was accepted “as is” with
its origins in the 1996 MORC; albeit, the early standard was remanded for remediation, largely on
format and structural grounds.
In 2013, FERC accepted remediations to BAL-002-WECC-2.
In 2017, an interpretation was added (BAL-002-WECC-2a) and later incorporated into BAL-002-WECC3, in which Requirement R2 was approved for retirement, with an effective date of August 15, 2019.
In 2025, the Western Interconnection still adheres to similar levels of reserves as it did in 1996. This
means that, for over 28 years, the Western Interconnection has held more reserves than the rest of the
continent (NERC BAL-002-3) even though there has never been technical justification to do so.

The Western Systems Coordinating Council (WSCC) was formed in 1967 by 40 power systems to coordinate the
planning and operations of the electric system in western North America. The WSCC's goal was to provide
reliable power to the public.
8

7

WECC-0142 BAL-002-WECC-3—Contingency Reserve—Request to Retire

Development History (Before 1996 to 2024)
Before 1996, members of the WSCC voluntarily operated the Western Interconnection according to the
MORC.9 Although the MORC contained provisions for generation control, generation performance,
and Contingency Reserve, the MORC provided no technical support for the reserve thresholds and
characteristics it set.10 Rather, the operating thresholds were established by negotiation—not technical
analysis. If this approach were adopted today, FERC would likely deny approval of the standard as
contrary to FERC Order 672, P329.11
In July and August of 1996, the Western Interconnection experienced two widespread outages resulting
from improper vegetation management. The resulting outage reports12 13 made several
recommendations that would later be adopted in the 1999 WECC RMS.14 15 The WECC Operating
Committee’s recommendation produced portions of the RMS that later evolved into WECC Standard
BAL-STD-002-0, Operating Reserves and, ultimately, BAL-002-WECC-3. Like the other initial

MORC, Maintenance Coordination: 1. Sharing information. The security and reliability of the interconnected
power system depends upon periodic inspection and adequate maintenance of generators, transmission lines and
associated equipment, control equipment, communication equipment, relaying equipment, and other system
facilities. Entities and coordinated groups of entities must establish procedures and responsibility for
disseminating information on scheduled outages and for coordinating scheduled outages of major facilities which
affect the security and reliability of the interconnected power system.
10 Minimum Operating Reliability Criterion, Section 1, Generation Control and Performance
11 FERC Order 672. P329. The proposed Reliability Standard must not simply reflect a compromise in the ERO’s
Reliability Standard development process based on the least effective North American practice—the so‐called
“lowest common denominator”—if such practice does not adequately protect Bulk‐Power System reliability.
Although the Commission will give due weight to the technical expertise of the ERO, we will not hesitate to
remand a proposed Reliability Standard if we are convinced it is not adequate to protect reliability.
12 The outage reports are available upon request. Western Systems Coordinating Council (WSCC) Disturbance
Report for the Power System Outage that Occurred on the Western Interconnection August 10, 1996, as approved
by the WSCC Operations Committee on October 18, 1996
13 “f. The WSCC Operations Committee shall assess whether the levels and allocation of operating reserves
contributed to the severity of this disturbance and implement corrective measures as appropriate.” Western
System Coordinating Council Disturbance Report, For the Power System Outages that Occurred on the Western
Interconnection on 2 JUL 1996. Approved by the WSCC Operations Committee on September 19, 1996. RMS
Outage Report, page 14.
14 The RMS was approved 1 SEP 1999. WECC Comment Report – WECC Tier 1- RMS Standard – (BAL-STD-002-0)
Question 4, Attachment 2, page 9.
15 “The majority of these standards were specifically developed to address and mitigate main causes of the two
major system outages that occurred in the Western Interconnection in July and August of 1996.” Agenda Item 3,
Board of Trustees Meeting, March 12, 2007, page 4
9

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WECC-0142 BAL-002-WECC-3—Contingency Reserve—Request to Retire
standards, the language of the original standard was a translation of the language contained in the
RMS.16
In March 1997, noting that federal remedial legislation could take years to enact, the WSCC trustees
created the WSCC RMS Policy Group17 establishing a contract-based operational system known as the
RMS.18 19 In establishing the RMS, the WSCC RMS Policy Group reviewed all NERC and WECC
reliability criteria, identified specific criteria deemed critical for reliability management, then moved
those criteria into the RMS through a three-phase implementation plan.20
On April 14, 1999, FERC asserted jurisdiction over the RMS.
Between September 1998 and February 2000 (phase two of the three-phase RMS implementation), the
WSCC turned the content of the RMS into the first mandatory reliability standards (aka Version Zero,
2007). BAL-SDT-002-0, Contingency Reserve was part of that translation.
On December 22, 2006, WECC submitted a request to NERC to approve, and send to FERC for
approval, eight proposed RRSs. WECC referred to the eight proposed standards as its Tier One

WECC states that the proposed regional Reliability Standards, which are exact translations of existing regional
criteria, either address matters not addressed in the Commission-approved ERO Reliability Standards or contain
more stringent requirements than the ERO standards. (FERC accepted Tier One standards evolving from the
RMS. AKA: Tier One Order.) FERC, 119 FERC ¶ 61,260 United States of America, Federal Energy Regulatory
Commission, Order Approving Regional Reliability Standards for the Western Interconnection and Directing
Modifications (Issued June 8, 2007), page 19.
16

Following the enactment of EPAct 2005 and the establishment of mandatory Reliability Standards applicable to
all owners, operators, and users of the BPS, WECC sought to translate certain of its existing practices under its
RMS reliability criteria into regional Reliability Standards to supplement the continent-wide Reliability Standards
the Commission approved in Order No. 693. To that end, WECC established a task force to identify criteria in the
RMS that should be binding on all BPS users, owners, and operators in the Western Interconnection, not just the
Transmission Operators subject to the RMS. The task force chose eight of the identified criteria, which had the
highest priority and could be implemented in the near term for translation into regional Reliability Standards.
United States of America Before the Federal Energy Regulatory Commission, North American Electric Reliability
Corporation (NERC), Docket No. RM16-10-000, Supplemental Information for Petition of the NERC and WECC
for Approval of retirement of Regional Reliability Standard TOP-007-WECC-1a, page 5.
17

18

Hearing

Electric Reliability Corporation, Helping Owners, Operators, and Users of the Bulk Power System Assure
Reliability and Security for More Than 50 Years, By David Nevius, Senior Vice President 1979–2012, Page 40-41.
19

20

Hearing

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WECC-0142 BAL-002-WECC-3—Contingency Reserve—Request to Retire
standards originating from the RMS because the proposed standards were translations of standards
that were already mandatory within the Western Interconnection as part of the RMS.21
Those eight standards—that included Tier One WECC-BAL-STD-002-0 (Operating Reserves)—were
near-exact translations of existing WECC criteria that FERC earlier accepted as part of the WECC RMS
program.22 Because the content was a near-exact translation, the format did not match that required by
NERC/FERC. This would later lead to a remand of BAL-002-WECC-1 to ensure conformity.
On January 9, 2007, NERC provided WECC with a report of its preliminary findings about the request
from December 22, 2006, and provided WECC with a list of required remediations.23 The request
largely addressed styles, formats, and corrections to compliance sections. The NERC Board of Trustees
approved the Tier One request subject to remediation and sent the eight proposed standards to FERC
with a request for approval.
In June 2007, FERC approved WECC’s submittal of eight reliability-crucial Tier One standards, thereby
transitioning from the RMS system to that of FERC-approved NERC Reliability Standards.24 Although
earlier versions lacked technical support, FERC agreed with
“WECC, WIRAB [Western Interconnection Regional Advisory Board] and NERC that
approval of [WECC’s early BAL] under section 215 would enhance reliability in the
Western Interconnection by making WECC’s current practices binding on all relevant
entities in the region and by strengthening WECC’s compliance and enforcement
authority.”25

North American Electric Reliability Corporation, Docket No. RR07-___-000, III. BACKGROUND ON THE
DEVELOPMENT OF THE WECC REGIONAL RELIABILITY STANDARDS, Debra A. Palmer of Schiff/Hardin
(1666 K STREET N.W., SUITE 300, WASHINGTON, DC 20006) on March 26, 2007.
22 Loc. Cit. IV. Overview of the Proposed WECC Regional Reliability Standards, page 6.
23 NERC DECISION APPROVING, WITH CONDITIONS, RELIABILITY STANDARDS PROPOSED BY
WESTERN ELECTRICITY COORDINATING COUNCIL, page 2. (Approved by Board of Trustees March 12,
2007)
24FERC Order Approving Regional Reliability Standards for the Western Interconnection and Directing
Modifications, Docket No. RR07-11-000, (Issued June 8, 2007)
25 Tier One Order, p. 43. See also, “The proposed regional Reliability Standards would make eight of those RMS
criteria binding on the applicable subset of users, owners and operators of the Bulk-Power System in the United
States portion of the Western Interconnection, as identified in each proposed standard. The regional Reliability
Standards would supplement rather than replace the Commission-approved Reliability Standards developed by
the ERO that will take effect in June 2007. Tier One, p. 10.
21

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WECC-0142 BAL-002-WECC-3—Contingency Reserve—Request to Retire

Structural Overview of BAL-002-WECC-3
Purpose
The Purpose of currently effective RRS BAL-002-WECC-3—Contingency Reserve is to provide an RRS
specifying “the quantity and types of Contingency Reserve required to ensure reliability under normal
and abnormal conditions.”26
The NERC Glossary defines Contingency Reserve as:
“The provision of capacity that may be deployed by the Balancing Authority to respond to a Balancing
Contingency Event and other contingency requirements (such as Energy Emergency Alerts as specified
in the associated EOP standard). A Balancing Authority may include in its restoration of Contingency
Reserve readiness to reduce Firm Demand and include it if, and only if, the Balancing Authority:
•

is experiencing a Reliability Coordinator declared Energy Emergency Alert level and is utilizing
its Contingency Reserve to mitigate an operating emergency in accordance with its emergency
Operating Plan.

•

is utilizing its Contingency Reserve to mitigate an operating emergency in accordance with its
emergency Operating Plan.”

Applicability
BAL-002-WECC-3 applies to Balancing Authorities (BA), unless the BA is a member of a Reserve
Sharing Group (RSG), in which case the RSG becomes the applicable entity.

Requirements
The standard consists of four requirements.
Requirement R1
•

Provides that each BA and RSG must maintain a minimum amount of Contingency Reserve,
except within the first sixty minutes following an event requiring the activation of Contingency
Reserves, and that the Contingency Reserve must consist of any combination of a list of
specified reserve types.

Requirement R2
•

26

Reserved. Retired, subject to cyclical field tests.

BAL-002-WECC-3, Contingency Reserve, Purpose.

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WECC-0142 BAL-002-WECC-3—Contingency Reserve—Request to Retire
Requirement R3
•

Each Sink BA and RSG must maintain an amount of Operating Reserve, in addition to the
minimum Contingency Reserve in Requirement R1, equal to the amount of Operating Reserve–
Supplemental for any Interchange Transaction designated as part of the Source Balancing
Authority’s Operating Reserve–Supplemental or source Reserve Sharing Group’s Operating
Reserve–Supplemental, except within the first sixty minutes following an event requiring the
activation of Contingency Reserve.

Requirement R4
•

Each Source BA and RSG must maintain an amount of Operating Reserve, in addition to the
minimum Contingency Reserve amounts identified in Requirement R1, equal to the amount
and type of Operating Reserves for any Operating Reserve transactions for which it is the
Source BA or RSG.

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WECC-0142 BAL-002-WECC-3—Contingency Reserve—Request to Retire

Reliability will be Maintained
Upon retirement of BAL-002-WECC-3, reliability will be maintained by NERC BAL-002-3, Disturbance
Control Standard—Contingency Reserve for Recovery from a Balancing Contingency Event, reinforced
by the enhanced availability of resources currently unavailable under BAL-002-WECC-3.
Replacing BAL-002-WECC-3 with NERC BAL-002-3 Mitigates Reliability Gaps associated
with Variable Generation
As highlighted by FERC in its Order 901, with the growing amount of variable generation replacing
more responsive and dispatchable resources, the industry faces the dilemma of how to support these
new resources.27 Unlike traditional resources, much of the new variable generation cannot be quickly
dispatched, thus creating a gap in reliability. FERC acknowledged that gap, noting that neither
business as usual nor existing reliability standards will remedy this concern. Finally, FERC also
recognizes the value that steps taken must apply on a continent-wide basis.28
Replacing BAL-002-WECC-3 with the continent-wide NERC BAL-002-3 takes immediate steps towards
meeting FERC’s concerns.
In Order 901, FERC states:
“[W]e continue to find that as the resource mix trends towards higher penetrations of IBRs, the
need to reliably integrate these resources into the Bulk-Power System is expected to grow, and
that the currently effective Reliability Standards do not adequately address IBR reliability risks.
The continuing risks that the increasing penetration of IBRs pose to the reliable operation of the BulkPower System underscore the need for mandatory Reliability Standards to address these issues on a
nationwide basis.” (Emphasis added.) Order 901, P24.
When BAL-002-WECC-3 is retired and replaced with NERC BAL-002-3, the amount and type of
reserves required to be held back within the Western Interconnection will decrease. That frees those
resources to be plied against load. Within the Western Interconnection, a vast majority of these
sequestered resources are immediately dispatchable (such as hydro), thus serving as the perfect
resource to match the less predictable response of variable generation.

FERC Order 901, P11-15, 185 FERC ¶ 61,042, United States of America, Federal Energy Regulatory Commission
(FERC), 18 CFR Part 40, Docket No. RM22-12-000; Reliability Standards to Address Inverter-Based Resources,
October 19, 2023. Hereafter: Order 901
28 Order 901, P24.
27

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WECC-0142 BAL-002-WECC-3—Contingency Reserve—Request to Retire
By making these dispatchable resources more operationally available, the secondary benefits may be to
bolster the supply of generation to the market. This potential secondary benefit directly addresses vital
public interests.29
Dispatchable Resources Contribute Significantly to Essential Reliability Services (ERS) 30
ERSs consist of frequency control, ramping capability, and voltage control.
Frequency control is necessary because the electric grid is designed to operate at a frequency of 60 hertz
(Hz). Deviations from 60 Hz can have destructive effects on generators, motors, and equipment of all
sizes and types. It is critical to maintain and restore frequency after a disturbance such as the loss of
generation. This requires an instantaneous (inertial) response from some resources and a fast response
from other resources to slow the rate of fall during the arresting period, a fast increase in power output
during the rebound period to stabilize the frequency, and a more prolonged contribution of additional
power to compensate for lost resources and bring system frequency back to the normal level. Two
NERC Reliability Standards address this:
•

BAL-002-3 Disturbance Control Standard—Contingency Reserve from a Balancing Contingency
Event

•

BAL-003-2 Frequency Response and Frequency Bias Setting

Adequate ramping capability (the ability to match load and generation at all times) is necessary to
maintain system frequency. Changes to the generation mix or the system operator’s ability to adjust
resource output can impact the ability of the operator to keep the system in balance. NERC Reliability
Standard BAL-001-2 (Real Power Balancing Control Performance) addresses this issue.
Voltage must be controlled to protect system reliability and move power where it is needed in both
normal operations and following a disturbance. Voltage issues tend to be local in nature, such as in
sub-areas of the transmission and distribution systems. Reactive power is needed to keep electricity
flowing and maintain necessary voltage levels. Several NERC Reliability Standards address voltage
control.
Restated, replacing BAL-002-WECC-3 with NERC BAL-002-3 frees dispatchable resources to address
FERC-identified reliability gaps created by variable generation, and may bolster vital public interests.

“335. Finally, we understand that at times development of a proposed Reliability Standard may require that a
particular reliability goal must be balanced against other vital public interests, such as environmental, social, and
other goals. We expect the ERO to explain any such balancing in its application for approval of a proposed
Reliability Standard. “ (Emphasis added.) Order 693, P35.
30 “Essential Reliability Services (ERS) are the elemental ‘reliability building blocks’ from resources (generation
and demand) necessary to maintain Bulk Power System (BPS) reliability.” NERC ERS Task Force – Scope – 2014.
29

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WECC-0142 BAL-002-WECC-3—Contingency Reserve—Request to Retire
Because adequate levels of reserves are established in NERC BAL-002-3, and supported by BAL-003-2,
BAL-002-WECC-3, Requirements R1 through R4 are not needed.
Replacing BAL-002-WECC-3 With NERC BAL-002-3 Provides Sufficient Reserves at a
Continent-Wide Level
In the earliest stages of the Western Interconnection’s strides to establish adequate Contingency
Reserves, the applicable entity’s reserves were established by BAL-STD-002-0, Operating Reserves, at
5% of hydro generation and 7% thermal generation (50% spinning and 50% non-spinning).31 These
thresholds were not technically supported; they were the result of contractual negotiations. Today,
such a standard would likely not be approved by FERC as violative of the principles established in
FERC Order 672. (See foot note 2.)
As BAL-STD-0-2 was replaced with later iterations of that standard, the result was today’s BAL-002WECC-3, in which the Responsible Entity’s reserves are set at:
R1.1.1 “The greater of either:
•

The amount of Contingency Reserve equal to the loss of the most severe single contingency;32
(or)

•

The amount of Contingency Reserve equal to the sum of three percent of hourly integrated
Load plus three percent of hourly integrated generation.”

Bullet one of BAL-002-WECC-3 describes the Most Severe Single Contingency, or MSSC.
The MSSC ensures that all entities can recover Area Control Error (ACE) within 15 minutes. The MSSC
serves as the upper Contingency Reserve threshold for all interconnections, except the Western
Interconnection. Within the Western Interconnection, the levels of reserve set by BAL-002-WECC-3 can
exceed that of the rest of the continent that is protected by FERC-approved BAL-002-3. As a result, the
Western Interconnection carries an excess of reserve that exacerbates concerns raised by FERC in Order
901 wherein FERC addresses the need for continent-wide standards to backstop the operational
performance of variable generation. Comparing NERC BAL-002-3 with BAL-002-WECC-3 illustrates
this outcome.
NERC BAL-002-3 states that the BA and the RSG are not subject to compliance with BAL-002-3, R1 for
multiple events that exceed the MSSC. NERC BAL-002-3 requires the applicable entity to deploy
Contingency Reserve up to its MSSC; however, it does not require Contingency Reserve deployment
beyond MSSC.

See Attachment - Transition from 5-7 to 3-3, as described in 2005 by Merrill Schultz; see also Attachment History of WECC Reserve 5-7 Spin Merrill Schultz, March 3, 2005; see also BAL-STD-002-0, Operating Reserves.
32 Also known as the Most Severe Single Contingency (MSSC).
31

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WECC-0142 BAL-002-WECC-3—Contingency Reserve—Request to Retire
By contrast, BAL-002-WECC-3 requires the applicable entity to maintain a level of Contingency
Reserves exceeding that required under NERC BAL-002-3, as approved by FERC. Specifically, BAL-002WECC-3, Requirement R1 requires the applicable entity to carry reserves that equal or exceed the
entity’s MSSC—beyond that required by BAL-002-3 that adequately serves the balance of the continent.
Among other things, this means these valuable dispatchable resources in excess of the MSSC cannot be
used to meet FERC’s goal of backstopping variable resources as identified in FERC Order 901.
While the application of BAL-002-3 could free resources to enhance reliability, the application of BAL002-WECC-3 can inhibit reliability when resources are withheld that could otherwise serve load and
backstop variable resources.
For example:
Using historical data from January 2020 - May 2024, comparison of the hourly Contingency Reserve
Requirement (calculated using 3% generation and 3% load) to the Most Severe Single Contingency
(MSSC), the results identified there was more than 5,000 MW of capacity available during the
summertime peak hours and between 2,000-2,500 MW during the remaining hours of the year. See
figure below.

Figure 1: Reserves in excess of MSSC

The Shortened Execution Time of BAL-002-WECC-3 Inhibits Reliability Due to Market
Rules in the Western Interconnection
BAL-002-WECC-3, Requirements R3 and R4 require the applicable entity to restore Contingency
Reserve within 60 minutes of the initiating event. By contrast, BAL-002-3 requires the applicable entity
to achieve the same task in 105 minutes. As a result, BAL-002-WECC-3 requires the performance of the
same task 45 minutes earlier than its continent-wide counterpart. This shortened period inhibits
reliability in that it forces the applicable entities into transactions agreed upon during an arbitrarily
shortened time window. Like BAL-002-3, Requirement R1., there is no technical support suggesting

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WECC-0142 BAL-002-WECC-3—Contingency Reserve—Request to Retire
that rushing this transaction enhances reliability—yet it remains in force 28 years after its inception,
still lacking any technical support.
Further, the restoration of reserves in a 60-minute timeframe is restrictive on the entity’s ability to
secure additional resources within the established business practices in the region. The NERC Standard
of up to 105 minutes (90 minutes after the 15 minutes Contingency Recovery Period) after the event has
less commercial impact and is acceptable from both a commercial standpoint as well as an operational
standpoint.
The WECC requirement of 60 minutes from start of a DCS event restricts the deficient entity from
rescheduling resources to replace those that were lost during the event. Western market practices
require schedules to be submitted and approved well in advance to ensure reliability, and once the
schedule windows close, it is difficult to make last-minute changes. Before markets, when transactions
were bilateral, a recovery of generation resources was more flexible, and could be more quickly
executed.
The NERC BAL-002-3 Contingency Reserve Restoration Period of up to 105 minutes allows applicable
entities to use normal market scheduling practices to replace lost generation. FERC’s approval of NERC
BAL-002-3 shows its belief that the NERC standard of 105 minutes (90 plus 15) is adequate and does
not degrade reliability.
In attempting to meet the 60-minute restoration requirement, the applicable entity has two options.
First, the BA must carry significantly more Contingency Reserve than is required to maintain an
adequate level of reliability, or second, be prepared to enter an Energy Emergency Alert 3 which allows
the BA to deploy Contingency Reserves to serve load. By definition, entering into an Energy
Emergency Alert is an indication of reduced reliability. Given normal scheduling practices, a 90-minute
restoration time allows a Responsible Entity to restore Contingency Reserve using normal established
market scheduling practices.
In addition, many entities own BES equipment in more than one interconnection. Having a single
standard enhances these entities’ ability to stay in compliance with the standard using consistent
business practices across the interconnections.
Reserve Thresholds do Not Reflect Resource Mix
Due to the changing resource mix and the proliferation of renewable generation, battery storage, and
retirements of conventional synchronous generation, resource adequacy has become a serious concern.
The BAL-002-WECC standard unnecessarily ties up significant generation which is dispatchable,
frequency responsive and fast ramping. Generation that could be used to meet ramps, follow variable
resources, or simply meet expected loads, is committed to contingency reserve capacity that is not
available to serve load. For example, Western Power Pool’s Northwest Power Pool Reserve Sharing
Group Northwest-Montana zone typically has a 1,200 MW MSSC, yet routinely has over 3,000 MW of

WECC-0142 BAL-002-WECC-3—Contingency Reserve—Request to Retire
reserves being held under the 3/3 requirement. That available capacity, usually in excess 1,800 MW,
could be used to meet other reliability related services obligations. The existing 3/3 contingency reserve
requirement results in the construction of at least 1800 MW of excess generation in the NorthwestMontana zone. The ability to use this generation capacity exceeding the MSSC will also allow entities to
efficiently operate their facilities. Idled excess capacity will be reduced and productive generation
increased.
Under NERC standard NERC BAL-002-3, the Eastern, Texas and Quebec Interconnections operate
without the additional reserve requirement (3% load and 3% generation), and they are allowed to
restore their reserves within 90 minutes. The changing market structure in the Western Interconnection
has made it difficult to fully restore the required reserves within 60 minutes due to market scheduling
timelines. This can lead to implementation of emergency procedures, typically Energy Emergency Alert
3 conditions, due to an energy shortfall precipitated by the 60-minute recovery period. When the
Western markets were mostly bilateral, the 60-minute recovery was consistent with energy scheduling
protocols. Market integration has altered energy scheduling protocols making it very difficult to
modify schedules within 60 minutes of a generation contingency. For these reasons BAL-002-WECC-3
has become obsolete, while not enhancing reliability.
Reserves are unused or unloaded generation that are in a state of readiness in case there is sudden loss
of loaded generation. When reserves are held above the MSSC, as they are in the Western
Interconnection, excess capacity must be built that has no other reliability benefit. Every energy
customer in the West absorbs this excess cost. Retirement of BAL-002-WECC-3 reallocates these excess
resources to the benefit of the interconnection in the form of dispatchable, responsive, and available
resources to reliably integrate future variable resources, such as wind, solar, and other renewable
resources.

Vital Public Interests will be Enhanced33 34
Market Timing Issues
The emergence of organized markets in WECC, since the inception of BAL-002-WECC-1 has brought a
new dynamic in the timing and means by which the reserves are procured. The number of participants
in the California ISO Energy Imbalance Market (AKA: Western Energy Imbalance Market, or WEIM)

“Finally, we understand that at times development of a proposed Reliability Standard may require that a
particular reliability goal must be balanced against other vital public interests, such as environmental, social, and
other goals. We expect the ERO to explain any such balancing in its application for approval of a proposed
Reliability Standard.” FERC Order No. 672 at P 335.
34 “The proposed Reliability Standard does not necessarily have to reflect the optimal method, or “best practice,”
for achieving its reliability goal without regard to implementation cost or historical regional infrastructure design.
It should however achieve its reliability goal effectively and efficiently.” FERC Order No. 672 at P 328.
33

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WECC-0142 BAL-002-WECC-3—Contingency Reserve—Request to Retire
has grown significantly in the past several years. CAISO EIM market rules require a participating BA to
balance its resources and loads 75 minutes before the next operating hour (T-75). Failure to do this can
result in financial penalties to the participating BA. This rule has had the effect of discouraging any
bilateral energy trading after T-75 and does not align well with a 60-minute reserve recovery time limit.
No bilateral trading for replacement energy reserve is possible for the next operational hour because
participating WEIM BAs cannot participate in trades within T-75.
This leaves the contingent BA in a resource short position when the 60-minute contingency restoration
time expires. At this point, the contingent BA must activate emergency operating procedures up to
asking the Reliability Coordinator to declare an EEA3, including load shedding to balance the
contingent BA. By extending the contingency restoration time to 105 minutes (15-minute recovery plus
90-minute restoration), the contingent BA has at least 30 minutes to arrange replacement energy in a
bilateral manner from other BAs or schedule their own resource in the WEIM. The additional
contingency reserve recovery time allows the contingent BA to make orderly and planned adjustments
and continue to serve firm load without the implementation of emergency operating procedures, up to
and including shedding firm load.
FERC and the industry have determined that 90 minutes from the end of the recovery period (up to 15
minutes) is sufficient to maintain an adequate level of reliability. The shorter restoration period in the
WECC creates artificial reliability issues as the applicable entity tries to rebalance supply and demand
in an arbitrarily shorter period than that required in the NERC BAL-002-3.
To give a clear understanding of the impact of either option, the following example is provided.
Assume the NWPP RSG’s MSSC is approximately 1,200 MW. Under BAL-002-WECC-3, the NWPP RSG
would normally carry approximately 2,200-4,000 MW of Contingency Reserves depending on the time
of year. Assuming the MSSC occurs, the NWPP RSG would activate 1,200 MW of its reserves and
restore the ACE to the pre-event level. Members now have approximately 60 minutes to restore 1,200
MW of reserves while still carrying more than 1,000–2,800 MW, which is greater than the MSSC,
assuming it was not reduced with the loss of the 1,180 MW event. See figure below.

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WECC-0142 BAL-002-WECC-3—Contingency Reserve—Request to Retire

Figure 2: Reserves in excess of MSSC; January 1, 2020, through May 1, 2024

As discussed earlier, due to market rules related to the WEIM in which most entities are taking part,
new resources cannot be added to an entity’s reserves for the next hour (minimum time to add a
resource under the WEIM (75 minutes), or other emerging markets. If a resource is not already in the
WEIM, it cannot count toward the reserves needed. So, an entity must have already been carrying
reserves greater than required under the WECC standard, or it must reduce load to balance its
resources and loads including reserves. (It can be argued that by reducing loads, you are putting the
interconnection at greater risk because you have removed one available resource, the load, from being
an option for the next event.) To avoid the declaration of an EEA, the NWPP would need to carry an
additional 1,000 MW above the required reserves or declare an EEA any time the reserves need to be
restored within 60 minutes of the event.
When entities withhold extra reserves to avoid the EEA, this paradigm keeps 2,500 to 4,000 MW from
serving load due to the WECC current standard, which has no technical merit, as compared to the
NERC Standard. These additional resources could be used to help integrate more inverter-based
resources and serve loads more efficiently if it were available for load service.
Entering an Energy Emergency Alert indicates reduced reliability. Given normal scheduling practices,
which require bilateral schedules to be completed and approved 75 minutes before the hour, a 60minute restoration time does not allow adequate time for a Responsible Entity to restore Contingency
Reserve in less than 60 minutes from the initiating event, potentially resulting in an Energy Emergency
Alert situation.

Capacity Could be Better Used than Simply Holding Reserve
FERC and the industry have determined that the amount of Contingency Reserve needed to maintain
an adequate level of reliability is the amount of Contingency Reserve needed to replace the MSSC
resource. Holding Contingency Reserve more than MSSC precludes using operating reserve for other
purposes, particularly load and resource balancing in real-time. As the grid transitions from

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WECC-0142 BAL-002-WECC-3—Contingency Reserve—Request to Retire
conventional synchronous generation to more variable renewable resources, increasing capacity will be
needed to manage the variability and faster ramping requirement of these resources. Allocating
reserves in excess of that needed to maintain an adequate level of reliability, or MSSC, ultimately
detracts from reliability.

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WECC-0142 BAL-002-WECC-3—Contingency Reserve—Request to Retire

Conclusion
Retirement of BAL-002-WECC-3 Contingency Reserve would reduce required reserves in WECC
without diminishing the ability to meet the deployment requirement. Freeing up reserves from the
Contingency Reserve requirement would increase the resources available to manage variable resources
and accommodate increased renewable resource integration.
The existing BAL-002-WECC-3 Contingency Reserve sets a BA’s or RSG’s Contingency Reserve
requirement to the greater of the MSSC or 3% of the applicable entity’s generation and 3% of its load.
This 3/3 requirement exceeds MSSC for most responsible entities.
By contrast, NERC Standard BAL-002-3 Disturbance Control Standard—Contingency Reserve for
Recovery from a Balancing Contingency Event, Requirement R1.3.2 states that the BA/RSG is not
subject to compliance with Requirement R1 for multiple events that exceed the MSSC. NERC BAL-0023 requires the applicable entity to deploy Contingency Reserve up to the MSSC but does not require
Contingency Reserve deployment beyond the MSSC.
In BAL-002-3, FERC and the industry have determined that the amount of Contingency Reserve
needed to maintain an adequate level of reliability is the amount of Contingency Reserve needed to
replace the MSSC resource.
Holding Contingency Reserve more than MSSC precludes using operating reserve for other purposes,
particularly load and resource balancing in real time. As the grid transitions from conventional
synchronous generation to more variable renewable resources, increasing capacity will be needed to
manage the variability and faster ramping requirement of these resources. Allocating reserve in excess
of that needed to maintain an adequate level of reliability, or MSSC, ultimately detracts from reliability.
BAL-002-WECC-3 requires an applicable entity to restore Contingency Reserve within 60 minutes of
the initiating event (as opposed to up to 105 minutes in BAL-002-3), or 45 minutes sooner than required
by BAL-002-3. With respect to impacts to the time to restore Contingency Reserve, FERC and the
industry have determined that 90 minutes from the end of the recovery period (up to 15 minutes) is
sufficient to maintain an adequate level of reliability. By contrast, the 60-minute requirement within
BAL-002-WECC-3 creates potential reliability issues as an applicable entity tries to rebalance in an
arbitrarily shorter period than that required in the NERC BAL-002-3. In attempting to meet the 60minute restoration requirement, an applicable entity has two options. First, the BA must carry
significantly more Contingency Reserve than is required to maintain an adequate level of reliability, or
second, be prepared to enter an Energy Emergency Alert 3 and deploy Contingency Reserve to serve
load. Given normal scheduling practices, a 90-minute restoration time allows an applicable entity to
restore Contingency Reserve without employing emergency procedures.
Retirement of BAL-002-WECC-3 will enhance the reliable operation of the Western Interconnection by
allowing resources that are presently used for overprotecting above the MSSC to be available to meet
22

WECC-0142 BAL-002-WECC-3—Contingency Reserve—Request to Retire
the immediate balancing needs of the Interconnection. This will free those resources to be used as
needed in a rapidly changing system to maintain overall reliability.

23

Attachment E – Project Roadmap
WECC-0142 BAL-002-WECC-3 Request to Retire

Project Roadmap
Actions

1.

Standard Authorization Request (SAR) Filed

2.

WECC Standards Committee (WSC) approved the SAR

3.

Drafting Team (DT) Solicitation

4.

WSC approves a Drafting Team

5.

DT Meeting

6.

DT Meeting (Subset)

7.

DT Meeting (Subset)

8.

DT Meeting

9.

DT Meeting

10.

DT Meeting

11.

DT Meeting

12.

DT Meeting

13.

DT Meeting

14.

DT Meeting

15.

DT Meeting

16.

DT Meeting

17.

DT Meeting

Completed

August 14, 2020
October 22, 2020
November 5, 2020
December 8, 2020
March 16, 2021
March 31, 2021
April 14, 2021
April 28, 2021
May 26, 2021
June 21, 2021
June 30, 2021
July 23, 2024
August 22, 2024
September 19, 2024
October 3, 2024
October 10, 2024
October 24, 2024

E LECTRIC R ELIABILITY AND S ECURITY F OR THE W EST

18.

DT Meeting

19.

Posting 1 Open

20.

Posting 1 Closed

21.

DT Meeting

22.

WSC Approved for Ballot

23.

Ballot Pool Open

24.

Ballot Pool Closed

25.

Standards Briefing Open Meeting

26.

Ballot Open

27.

Ballot Closed

28.

Passed Ballot Pool Approval

29.
WSC Approved for WECC Board of Directors (Board)
Disposition
30.
WECC Board Approved for NERC/FERC Filing
31.

NERC 45-Day Comment – Open

32.

NERC 45-Day Comment – Closed

33.

DT Meeting

34.

NERC Board of Trustees Approved

A TTACHEMENT E – P ROJECT R OADMAP WECC-0142

November 7, 2024
November 15, 2024
January 15, 2025
January 21, 2025
March 6, 2025
April 14, 2025
April 28, 2025
April 30, 2025
May 1, 2025
May 15, 2025
May 15, 2025
May 21, 2025
June 11, 2025
TBD
TBD
TBD
TBD

2

Regional Reliability Standards Announcement
Western Electricity Coordinating Council (WECC)
Proposed Retirement of BAL-002-WECC-3
Comment Period Open through October 30, 2025
Now Available

WECC requested that NERC post the proposed retirement of BAL-002-WECC-3 – Contingency Reserve
for industry review and comment in accordance with the NERC Rules of Procedure. A 45-day comment
period is open through 8 p.m. Eastern, Thursday, October 30, 2025.
Background

WECC recommends the retirement of Regional Reliability Standard BAL-002-WECC-3 in its entirety for
the reasons stated in the WECC-0142 BAL-002-WECC-3 Contingency Reserve Request to Retire white
paper, available here.
The retirement proposal was posted for comment by WECC November 15, 2024 - January 15, 2025 and
the comments received can be viewed here. The retirement was approved by the WECC Board of
Directors on June 11, 2025.
For more information, see the documents posted on the NERC Regional Standards Under Development
page. Additional materials can be found on the WECC Standards page.
Commenting

Use the Standards Balloting and Commenting System (SBS) to submit comments. Contact Alexandria
Myrick regarding issues with the SBS. An unofficial Word version of the comment form is posted on the
Regional Reliability Standards Under Development page.
•

Contact NERC IT support directly at https://support.nerc.net/ (Monday – Friday, 8 a.m. - 5 p.m.
Eastern) for problems regarding accessing the SBS due to a forgotten password, incorrect
credential error messages, or system lock-out.

•

Passwords expire every 6 months and must be reset.

•

The SBS is not supported for use on mobile devices.

•

Please be mindful of ballot and comment period closing dates. We ask to allow at least 48 hours
for NERC support staff to assist with inquiries. Therefore, it is recommended that users try logging
into their SBS accounts prior to the last day of a comment/ballot period.

RELIABILITY | RESILIENCE | SECURITY

Regional Reliability Standards Development Process

Section 300 of NERC’s Rules of Procedures of the Electric Reliability Organization governs the regional
reliability standards development process.

For more information or assistance, contact Reliability Standards Analyst, Wendy Muller (via email) or at
(404) 823-1366.
North American Electric Reliability Corporation
3353 Peachtree Rd, NE
Suite 600, North Tower
Atlanta, GA 30326
404-446-2560 | www.nerc.com

Unofficial Comment Form | Proposed Retirement of Regional Reliability Standard BAL-002-WECC-3
September-October, 2025

2

Unofficial Comment Form

Regional Reliability Standard – Retirement
BAL-002-WECC-3
DO NOT use this form for submitting comments. Use the electronic form to submit comments on the
proposed retirement of Regional Reliability Standard BAL-002-WECC-3 – Contingency Reserve. The
electric form must be submitted by 8 p.m. Eastern, Thursday, October 30, 2025.
If you have questions, contact Reliability Standards Analyst, Wendy Muller (via email) or at (404) 8231366.
Background Information

WECC recommends the retirement of Regional Reliability Standard BAL-002-WECC-3 in its entirety. For
more information, please see the documents posted on the NERC Regional Standards Under Development
page. Additional materials can be found on the WECC Standards page.
NERC Criteria for Developing or Modifying a Regional Reliability Standard

Each regional difference (i.e., Regional Reliability Standard or Variance) shall be: (1) is more stringent than
the continent-wide Reliability Standard, including a regional difference that addresses matters that the
continent-wide Reliability Standard does not; or (2) necessitated by a physical difference in the bulk
power system. Regional Reliability Standards and Variances shall provide for as much uniformity as
possible with Reliability Standards across the interconnected bulk power system of the North American
continent. Regional Reliability Standards and Variances, when approved by FERC and applicable
authorities in Mexico and Canada, shall be made part of the body of NERC Reliability Standards and shall
be enforced upon all applicable Bulk Power System owners, operators, and users within the applicable
area, regardless of membership in the region.
The approval process for a proposed Regional Reliability Standard or Variance, or the retirement of an
existing standard or Variance, requires NERC to publicly notice and request comment. Comments shall be
permitted only on the following criteria (technical aspects of the standard are vetted through the Regional
Standards Development Process):
Unfair or Closed Process – The Regional Reliability Standard was not developed in a fair and open process
that provided an opportunity for all interested parties to participate. Although a NERC-approved Regional
Reliability Standards development procedure shall be presumed to be fair and open, objections could be
raised regarding the implementation of the procedure.
Adverse Reliability or Commercial Impact on Other Interconnections – The Regional Reliability Standard
would have a significant adverse impact on reliability or commerce in other interconnections.
Deficient Standard – The Regional Reliability Standard fails to provide a level of reliability of the Bulk
Power System such that the Regional Reliability Standard would be likely to cause a serious and
substantial threat to public health, safety, welfare, or national security.

Adverse Impact on Competitive Markets within the Interconnection – The Regional Reliability Standard
would create a serious and substantial burden on competitive markets within the interconnection that is
not necessary for reliability.
Questions

1. Do you agree that the Regional Reliability Standards Development Procedure for retiring Regional
Reliability Standard BAL-002-WECC-3 was fair and open?
Yes
No
Comments:
2. Does the retirement of Regional Reliability Standard BAL-002-WECC-3 pose an adverse impact to
reliability or commerce in a neighboring region or interconnection?
Yes
No
Comments:
3. Does the retirement of Regional Reliability Standard BAL-002-WECC-3 pose a serious and
substantial threat to public health, safety, welfare, or national security?
Yes
No
Comments:
4. Does the retirement of Regional Reliability Standard BAL-002-WECC-3 pose a serious and
substantial burden on competitive markets within the interconnection that is not necessary for
reliability?
Yes
No
Comments:
5. Do you agree that Regional Reliability Standard BAL-002-WECC-3 is no longer needed to specify
more stringent criteria than a continent-wide standard, address matters not included in a
continent-wide standard, or address a physical difference in the bulk power system?
Yes
No
Comments:

Unofficial Comment Form | Proposed Retirement of Regional Reliability Standard BAL-002-WECC-3
September-October, 2025

2

Comment Report
Project Name:

Regional Reliability Standard (WECC) | Retirement of BAL-002-WECC-3

Comment Period Start Date:

9/16/2025

Comment Period End Date:

10/30/2025

Associated Ballots:

There were 14 sets of responses, including comments from approximately 36 different people from approximately 16 companies
representing 6 of the Industry Segments as shown in the table on the following pages.

Questions
1. Do you agree that the Regional Reliability Standards Development Procedure for retiring Regional Reliability Standard BAL-002-WECC-3
was fair and open?
2. Does the retirement of Regional Reliability Standard BAL-002-WECC-3 pose an adverse impact to reliability or commerce in a neighboring
region or interconnection?
3. Does the retirement of Regional Reliability Standard BAL-002-WECC-3 pose a serious and substantial threat to public health, safety,
welfare, or national security?
4. Does the retirement of Regional Reliability Standard BAL-002-WECC-3 pose a serious and substantial burden on competitive markets
within the interconnection that is not necessary for reliability?
5. Do you agree that Regional Reliability Standard BAL-002-WECC-3 is no longer needed to specify more stringent criteria than a continentwide standard, address matters not included in a continent-wide standard, or address a physical difference in the bulk power system?

Organization
Name

Name

Segment(s)

BC Hydro and Adrian Andreoiu 1,3,5
Power
Authority

Southwest
Power Pool,
Inc. (RTO)

Alan Wahlstrom 2

Tacoma Public Jennie Wike
Utilities
(Tacoma, WA)

Black Hills
Corporation

1,3,4,5,6

Rachel Schuldt 1,3,5,6

Region

WECC

MRO,WECC

WECC

Group Name

Group Member
Name

Group
Member
Organization

BC Hydro

Hootan Jarollahi

BC Hydro and 3
Power
Authority

WECC

Helen Hamilton
Harding

BC Hydro and 5
Power
Authority

WECC

Adrian Andreoiu

BC Hydro and 1
Power
Authority

WECC

Alan Wahlstrom

SPP

2

MRO

Alan Wahlstrom

SPP

2

WECC

Jennie Wike

Tacoma Public 1,3,4,5,6
Utilities

WECC

John Merrell

Tacoma Public 1
Utilities
(Tacoma, WA)

WECC

John Nierenberg

Tacoma Public 3
Utilities
(Tacoma, WA)

WECC

Hien Ho

Tacoma Public 4
Utilities
(Tacoma, WA)

WECC

Terry Gifford

Tacoma Public 6
Utilities
(Tacoma, WA)

WECC

Ozan Ferrin

Tacoma Public 5
Utilities
(Tacoma, WA)

WECC

SPP

Tacoma
Power

Black Hills
Corporation All Segments

Group
Member
Segment(s)

Group Member
Region

Trevor Rombough Black Hills
Corporation

1

WECC

Josh Combs

Black Hills
Corporation

3

WECC

Rachel Schuldt

Black Hills
Corporation

6

WECC

Carly Miller

Black Hills
Corporation

5

WECC

Sheila Suurmeier

Black Hills
Corporation

5

WECC

Sacramento
Municipal
Utility District

Tim Kelley

1,3,4,5,6

WECC

SMUD and
BANC

Nicole Looney

Sacramento
Municipal
Utility District

3

WECC

Charles Norton

Sacramento
Municipal
Utility District

6

WECC

Wei Shao

Sacramento
Municipal
Utility District

1

WECC

Foung Mua

Sacramento
Municipal
Utility District

4

WECC

Nicole Goi

Sacramento
Municipal
Utility District

5

WECC

Kevin Smith

Balancing
Authority of
Northern
California

1

WECC

1. Do you agree that the Regional Reliability Standards Development Procedure for retiring Regional Reliability Standard BAL-002-WECC-3
was fair and open?
Jennie Wike - Tacoma Public Utilities (Tacoma, WA) - 1,3,4,5,6 - WECC, Group Name Tacoma Power
Answer

Yes

Document Name
Comment
Tacoma Power concurs that the procedure was fair and open, and provided sufficient opportunity for entities to comment on the proposal. The white
paper supporting the WECC Standard Project 0142 also provides sufficient documentation and transparency for retiring this regional Standard.
Likes

0

Dislikes

0

Response
Tim Kelley - Sacramento Municipal Utility District - 1,3,4,5,6 - WECC, Group Name SMUD and BANC
Answer

Yes

Document Name
Comment
SMUD agrees that the procedure was fair and open, providing ample opportunity for stakeholders to comment on the proposal. Additionally, the white
paper supporting the WECC Standard Project 0142 offers sufficient documentation and transparency to support the retirement of this regional Standard.
Likes

0

Dislikes

0

Response
Jessica Cordero - Unisource - Tucson Electric Power Co. - 1
Answer

Yes

Document Name
Comment
Likes

0

Dislikes
Response

0

Kevin Conway - Western Power Pool - 4
Answer

Yes

Document Name
Comment
Likes

0

Dislikes

0

Response
Rachel Schuldt - Black Hills Corporation - 1,3,5,6, Group Name Black Hills Corporation - All Segments
Answer

Yes

Document Name
Comment
Likes

0

Dislikes

0

Response
Casey Perry - TXNM Energy - 1,3 - WECC,Texas RE
Answer

Yes

Document Name
Comment
Likes

0

Dislikes

0

Response
Donna Wood - Tri-State G and T Association, Inc. - 1,3,5
Answer
Document Name
Comment

Yes

Likes

0

Dislikes

0

Response
Adrian Andreoiu - BC Hydro and Power Authority - 1,3,5, Group Name BC Hydro
Answer

Yes

Document Name
Comment
Likes

0

Dislikes

0

Response
Cain Braveheart - Bonneville Power Administration - 1,3,5,6 - WECC
Answer

Yes

Document Name
Comment
Likes

0

Dislikes

0

Response
Daniela Atanasovski - APS - Arizona Public Service Co. - 1,3,5,6
Answer

Yes

Document Name
Comment
Likes

0

Dislikes
Response

0

Alan Wahlstrom - Southwest Power Pool, Inc. (RTO) - 2 - MRO,WECC, Group Name SPP
Answer

Yes

Document Name
Comment
Likes

0

Dislikes

0

Response
Justin Spear - Western Area Power Administration - 1,6
Answer

Yes

Document Name
Comment
Likes

0

Dislikes

0

Response
Darcy O'Connell - California ISO - 2
Answer

Yes

Document Name
Comment
Likes

0

Dislikes

0

Response
Jennifer Neville - Western Area Power Administration - 1,6
Answer
Document Name
Comment

Yes

Likes

0

Dislikes
Response

0

2. Does the retirement of Regional Reliability Standard BAL-002-WECC-3 pose an adverse impact to reliability or commerce in a neighboring
region or interconnection?
Tim Kelley - Sacramento Municipal Utility District - 1,3,4,5,6 - WECC, Group Name SMUD and BANC
Answer

No

Document Name
Comment
The retirement of this regional Standard will not negatively affect either reliability or market operations. As highlighted by the Western Power Pool in
their comments on WECC Standard Project 0142, the BAL-002-WECC-3 Standard imposes economic challenges and limits the ability to use
Contingency Reserves for additional reliability functions, such as accommodating variable generation and maintaining frequency response.
Furthermore, extending the restoration period from 60 to 90 minutes offers a more reasonable timeframe for recovery, enabling entities to replenish
contingency reserves more effectively after an event.
Likes

0

Dislikes

0

Response
Jennie Wike - Tacoma Public Utilities (Tacoma, WA) - 1,3,4,5,6 - WECC, Group Name Tacoma Power
Answer

No

Document Name
Comment
The retirement of this regional Standard does not adversely impact reliability or commerce. As noted by the Western Power Pool in the comments on
the WECC Project 0142, the BAL-002-WECC-3 Standard has adverse economic impacts and prevents the use of Contingency Reserve to support other
reliability needs, such as supporting variable resources and frequency response.
Lastly, the timing requirement change from 60 minutes to 90 minutes allows a more practical restoration period to recover from the event and restore
contingency reserve, which should decrease the numbers and level of a potential EEA3 since the entity will have time to assess more rational
restoration actions.
Likes

0

Dislikes

0

Response
Jennifer Neville - Western Area Power Administration - 1,6
Answer
Document Name

No

Comment
Likes

0

Dislikes

0

Response
Darcy O'Connell - California ISO - 2
Answer

No

Document Name
Comment
Likes

0

Dislikes

0

Response
Justin Spear - Western Area Power Administration - 1,6
Answer

No

Document Name
Comment
Likes

0

Dislikes

0

Response
Alan Wahlstrom - Southwest Power Pool, Inc. (RTO) - 2 - MRO,WECC, Group Name SPP
Answer

No

Document Name
Comment
Likes

0

Dislikes
Response

0

Daniela Atanasovski - APS - Arizona Public Service Co. - 1,3,5,6
Answer

No

Document Name
Comment
Likes

0

Dislikes

0

Response
Cain Braveheart - Bonneville Power Administration - 1,3,5,6 - WECC
Answer

No

Document Name
Comment
Likes

0

Dislikes

0

Response
Adrian Andreoiu - BC Hydro and Power Authority - 1,3,5, Group Name BC Hydro
Answer

No

Document Name
Comment
Likes

0

Dislikes

0

Response
Donna Wood - Tri-State G and T Association, Inc. - 1,3,5
Answer
Document Name
Comment

No

Likes

0

Dislikes

0

Response
Casey Perry - TXNM Energy - 1,3 - WECC,Texas RE
Answer

No

Document Name
Comment
Likes

0

Dislikes

0

Response
Rachel Schuldt - Black Hills Corporation - 1,3,5,6, Group Name Black Hills Corporation - All Segments
Answer

No

Document Name
Comment
Likes

0

Dislikes

0

Response
Kevin Conway - Western Power Pool - 4
Answer

No

Document Name
Comment
Likes

0

Dislikes
Response

0

Jessica Cordero - Unisource - Tucson Electric Power Co. - 1
Answer

No

Document Name
Comment
Likes

0

Dislikes
Response

0

3. Does the retirement of Regional Reliability Standard BAL-002-WECC-3 pose a serious and substantial threat to public health, safety,
welfare, or national security?
Jennie Wike - Tacoma Public Utilities (Tacoma, WA) - 1,3,4,5,6 - WECC, Group Name Tacoma Power
Answer

No

Document Name
Comment
No, the retirement does not pose a serious threat. Instead, this retirement would free up excess reserves being held above the MSSC requirements to
serve system demand. This additional available capacity would be better used to address issues associated with IBR integration and variable
generation.
Likes

0

Dislikes

0

Response
Tim Kelley - Sacramento Municipal Utility District - 1,3,4,5,6 - WECC, Group Name SMUD and BANC
Answer

No

Document Name
Comment
No, retiring this standard does not present a significant risk. In fact, it would allow reserves currently maintained above the Most Severe Single
Contingency (MSSC) requirements to be redirected to meet system demand more effectively.
Likes

0

Dislikes

0

Response
Justin Spear - Western Area Power Administration - 1,6
Answer

No

Document Name
Comment
Retiring this standard does not present a significant risk. Western Area Power Administration (WAPA) enthusiastically supports the retirement of the
BAL-002-WECC-3 standard. WAPA operates three Balancing Authorities (WALC, WACM, & WAUW) in the WECC footprint. Each of our BAs also
participate in the Northwest Power Pool reserve sharing group. This participation has allowed us to reduce our Contingency Reserve obligation while
maintaining reliability. All three BAs also participate in organized imbalance markets. Operating our BAs and meeting all the NERC reliability standards
efficiently and economically has become increasingly more difficult over the last few years. We have a finite amount of capacity on our federal hydro

resources to balance our loads and resources, maintain reliability, and satisfy our statutory delivery obligations. This constraint has been negatively
impacted by the prolonged drought in the West and the increase of Solar and Wind resources that have interconnected to our systems. By retiring the
more stringent WECC standard, WAPA would realize a significant reduction to the amount of capacity we would have to commit for Contingency
Reserves and would free up this capacity to manage the variability of existing and future variable renewable resources.
Likes

0

Dislikes

0

Response
Jennifer Neville - Western Area Power Administration - 1,6
Answer

No

Document Name
Comment
Retiring this standard does not present a significant risk. Western Area Power Administration (WAPA) supports the retirement of the BAL-002-WECC-3
standard. WAPA operates three Balancing Authorities (WALC, WACM, & WAUW) in the WECC footprint. Each of our BAs also participate in the
Northwest Power Pool reserve sharing group. This participation has allowed us to reduce our Contingency Reserve obligation while maintaining
reliability. All three BAs also participate in organized imbalance markets. Operating our BAs and meeting all the NERC reliability standards efficiently
and economically has become increasingly more difficult over the last few years. We have a finite amount of capacity on our federal hydro resources to
balance our loads and resources, maintain reliability, and satisfy our statutory delivery obligations. This constraint has been negatively impacted by the
prolonged drought in the West and the increase of Solar and Wind resources that have interconnected to our systems. By retiring the more stringent
WECC standard, WAPA would realize a significant reduction to the amount of capacity we would have to commit for Contingency Reserves and would
free up this capacity to manage the variability of existing and future variable renewable resources.
Likes

0

Dislikes

0

Response
Jessica Cordero - Unisource - Tucson Electric Power Co. - 1
Answer

No

Document Name
Comment
Likes

0

Dislikes

0

Response
Kevin Conway - Western Power Pool - 4

Answer

No

Document Name
Comment
Likes

0

Dislikes

0

Response
Rachel Schuldt - Black Hills Corporation - 1,3,5,6, Group Name Black Hills Corporation - All Segments
Answer

No

Document Name
Comment
Likes

0

Dislikes

0

Response
Casey Perry - TXNM Energy - 1,3 - WECC,Texas RE
Answer

No

Document Name
Comment
Likes

0

Dislikes

0

Response
Donna Wood - Tri-State G and T Association, Inc. - 1,3,5
Answer

No

Document Name
Comment
Likes

0

Dislikes

0

Response
Adrian Andreoiu - BC Hydro and Power Authority - 1,3,5, Group Name BC Hydro
Answer

No

Document Name
Comment
Likes

0

Dislikes

0

Response
Cain Braveheart - Bonneville Power Administration - 1,3,5,6 - WECC
Answer

No

Document Name
Comment
Likes

0

Dislikes

0

Response
Daniela Atanasovski - APS - Arizona Public Service Co. - 1,3,5,6
Answer

No

Document Name
Comment
Likes

0

Dislikes

0

Response
Alan Wahlstrom - Southwest Power Pool, Inc. (RTO) - 2 - MRO,WECC, Group Name SPP
Answer

No

Document Name
Comment
Likes

0

Dislikes

0

Response
Darcy O'Connell - California ISO - 2
Answer

No

Document Name
Comment
Likes

0

Dislikes
Response

0

4. Does the retirement of Regional Reliability Standard BAL-002-WECC-3 pose a serious and substantial burden on competitive markets
within the interconnection that is not necessary for reliability?
Jennifer Neville - Western Area Power Administration - 1,6
Answer

No

Document Name
Comment
WAPA supports extending the time requirement for restoring Contingency Reserves after an event from 60 minutes to 105 minutes. This approach
makes more operational and commercial sense. Western market practices have made the restoration of Contingency Reserves more challenging and
introduced more economic and operational risks.
Likes

0

Dislikes

0

Response
Justin Spear - Western Area Power Administration - 1,6
Answer

No

Document Name
Comment
WAPA supports extending the time requirement for restoring Contingency Reserves after an event from 60 minutes to 105 minutes. This approach
makes more operational and commercial sense. Western market practices have made the restoration of Contingency Reserves more challenging and
introduced more economic and operational risks.
Likes

0

Dislikes

0

Response
Alan Wahlstrom - Southwest Power Pool, Inc. (RTO) - 2 - MRO,WECC, Group Name SPP
Answer

No

Document Name
Comment
SPP does not believe the retirement of BAL-002 will pose a serious and substantial burden on competitive markets if there is a sufficient lead time for
implementation. Changing SPP’s market will require lead time for design, testing, and implementation. SPP is requesting at least an 18-month window
after approval to become effective to allow SPP sufficient time to address needed changes.

Likes

0

Dislikes

0

Response
Tim Kelley - Sacramento Municipal Utility District - 1,3,4,5,6 - WECC, Group Name SMUD and BANC
Answer

No

Document Name
Comment
SMUD agrees with WAPA’s comments on WECC Standard Project 0142 supporting the extension of the restoration period for Contingency Reserves
from 60 minutes to 105 minutes. Allowing additional time for restoration is more practical from both operational and commercial perspectives. The
existing requirements under BAL-002-WECC-3 have complicated the process of restoring Contingency Reserves and have introduced greater
economic and operational risks within western markets.
Likes

0

Dislikes

0

Response
Jennie Wike - Tacoma Public Utilities (Tacoma, WA) - 1,3,4,5,6 - WECC, Group Name Tacoma Power
Answer

No

Document Name
Comment
As noted by WAPA in the WECC Project 0142 comments, Tacoma Power supports extending the time requirement for restoring Contingency Reserves
after an event from 60 minutes to 105 minutes. This approach makes more operational and commercial sense. Western market practices under BAL002-WECC-3 have made the restoration of Contingency Reserves more challenging and introduced more economic and operational risks.
Likes

0

Dislikes

0

Response
Darcy O'Connell - California ISO - 2
Answer
Document Name
Comment

No

Likes

0

Dislikes

0

Response
Daniela Atanasovski - APS - Arizona Public Service Co. - 1,3,5,6
Answer

No

Document Name
Comment
Likes

0

Dislikes

0

Response
Cain Braveheart - Bonneville Power Administration - 1,3,5,6 - WECC
Answer

No

Document Name
Comment
Likes

0

Dislikes

0

Response
Adrian Andreoiu - BC Hydro and Power Authority - 1,3,5, Group Name BC Hydro
Answer

No

Document Name
Comment
Likes

0

Dislikes

0

Response
Donna Wood - Tri-State G and T Association, Inc. - 1,3,5

Answer

No

Document Name
Comment
Likes

0

Dislikes

0

Response
Casey Perry - TXNM Energy - 1,3 - WECC,Texas RE
Answer

No

Document Name
Comment
Likes

0

Dislikes

0

Response
Rachel Schuldt - Black Hills Corporation - 1,3,5,6, Group Name Black Hills Corporation - All Segments
Answer

No

Document Name
Comment
Likes

0

Dislikes

0

Response
Kevin Conway - Western Power Pool - 4
Answer

No

Document Name
Comment
Likes

0

Dislikes

0

Response
Jessica Cordero - Unisource - Tucson Electric Power Co. - 1
Answer

No

Document Name
Comment
Likes

0

Dislikes
Response

0

5. Do you agree that Regional Reliability Standard BAL-002-WECC-3 is no longer needed to specify more stringent criteria than a continentwide standard, address matters not included in a continent-wide standard, or address a physical difference in the bulk power system?
Daniela Atanasovski - APS - Arizona Public Service Co. - 1,3,5,6
Answer

No

Document Name
Comment
AZPS does not agree with the request to retire BAL-002-WECC-3 in its entirety. From 2019 to 2024, the Western Interconnection has experienced
several significant events impacting the Bulk Electric System such as extreme natural events, inverter-based resource events, and resource adequacy
that may have benefited from having additional reserves to respond to contingency events. The more stringent criteria in BAL-003-WECC-3 may have
alleviated some of these events.
Likes

0

Dislikes

0

Response
Jennie Wike - Tacoma Public Utilities (Tacoma, WA) - 1,3,4,5,6 - WECC, Group Name Tacoma Power
Answer

Yes

Document Name
Comment
Tacoma Power agrees with the Drafting Team that holding Contingency Reserves at a level of 3% load plus 3% generation is not technically supported
and is more than what is needed for BPS reliability in the western interconnection.
Likes

0

Dislikes

0

Response
Tim Kelley - Sacramento Municipal Utility District - 1,3,4,5,6 - WECC, Group Name SMUD and BANC
Answer

Yes

Document Name
Comment
SMUD concurs with the Drafting Team's assessment that maintaining Contingency Reserves at the level of 3% of load plus 3% of generation lacks
technical justification and exceeds what is necessary to ensure Bulk Power System reliability within the western interconnection.
Likes

0

Dislikes

0

Response
Cain Braveheart - Bonneville Power Administration - 1,3,5,6 - WECC
Answer

Yes

Document Name
Comment
BPA believes the current standard causes WECC entities to hold more contingency reserves than is necessary and allows only 60 minutes to fully
recover from an event. With the number of variable generation resources coming online, the capacity being unused by holding too much for
contingency reserve can be better allocated to ensure reliability of the interconnection and to help balance those variable energy resources. BPA
believes the timing required by the markets causes issues when trying to replenish reserves in the 60 minutes allocated. The 105 minutes allotted in
BAL-002-3 (90 minutes after the Contingency Event Recovery Period) is better suited for operations in a market environment. BPA agrees with the
rationale in the White Paper provided by the drafting team, as it offers a clear explanation and technical justification for the full retirement of BAL-002WECC-3.
Likes

0

Dislikes

0

Response
Alan Wahlstrom - Southwest Power Pool, Inc. (RTO) - 2 - MRO,WECC, Group Name SPP
Answer

Yes

Document Name
Comment
SPP agrees that the standard would no longer be needed provided that a technical study be conducted to evaluate whether the physical and
operational conditions that originally justified BAL-002-WECC-3 still exist. Such a study would provide the necessary evidence to support a retirement
decision and align with FERC’s historical expectations for technical justification in similar cases. To date, no technical study has been provided to
demonstrate that these conditions have materially changed or that the continent-wide standard alone is sufficient to maintain reliability in the region.

Likes

0

Dislikes

0

Response
Justin Spear - Western Area Power Administration - 1,6
Answer

Yes

Document Name
Comment
WAPA is concerned with maintaining a standard that is not proven, not evidence-based, and inconsistent with the rest of the continent.
Likes

0

Dislikes

0

Response
Jennifer Neville - Western Area Power Administration - 1,6
Answer

Yes

Document Name
Comment
WAPA is concerned with maintaining a standard that is not proven, not evidence-based, and inconsistent with the rest of the continent.
Likes

0

Dislikes

0

Response
Jessica Cordero - Unisource - Tucson Electric Power Co. - 1
Answer

Yes

Document Name
Comment
Likes

0

Dislikes

0

Response
Kevin Conway - Western Power Pool - 4
Answer
Document Name
Comment

Yes

Likes

0

Dislikes

0

Response
Rachel Schuldt - Black Hills Corporation - 1,3,5,6, Group Name Black Hills Corporation - All Segments
Answer

Yes

Document Name
Comment
Likes

0

Dislikes

0

Response
Casey Perry - TXNM Energy - 1,3 - WECC,Texas RE
Answer

Yes

Document Name
Comment
Likes

0

Dislikes

0

Response
Donna Wood - Tri-State G and T Association, Inc. - 1,3,5
Answer

Yes

Document Name
Comment
Likes

0

Dislikes

0

Response
Adrian Andreoiu - BC Hydro and Power Authority - 1,3,5, Group Name BC Hydro

Answer

Yes

Document Name
Comment
Likes

0

Dislikes

0

Response
Darcy O'Connell - California ISO - 2
Answer

Yes

Document Name
Comment
Likes

0

Dislikes
Response

0

Exhibit D
Standard Drafting Team Roster for WECC-0142

WECC-0142 Drafting Team Roster
BAL-002-WECC-3
Contingency Reserve Request to Retire
Drafting Team Roster

Name

Biography

Alan

Mr. Wahlstrom has extensive knowledge of the electric power industry

Wahlstrom,

primarily focused on transmission and generation engineering, operations,

Southwest

training and compliance with federally-approved reliability standards. His

Power Pool

experience includes real-time electric system operations, generation project
management and working knowledgeable of hydraulics, pneumatics, pumps,
and programmable logic controllers. He is a Trained Accident Investigator
and has investigated several industrial accidents to determine the cause and
how to prevent the accident from reoccurring. His current responsibilities
include investigation of transmission system events.
Work History
Southwest Power Pool Regional Entity (2008-Present), Little Rock, AR 72205
Lead Reliability Standards Engineer (2017-present)
•

Events Analyses Program Coordinator responsible for submitting events
to Regional Entities and NERC

•

Provide input to new or revised Regional and NERC standards

•

Review NERC and Regional Lessons Learned to determine if applicable
to SPP Operations and IT departments

•

Develop and perform training to SPP working groups

Lead Engineer, Event Analyst (2010-2017)
•

Report directly to the President of SPPRE

•

Analyze Bulk Power System events to determine the cause of an event,
track corrective actions to prevent recurrence, and provide lessons learned
to the industry.

•

Provide valuable input for training, education, reliability trend analysis
efforts, and reliability standards development, all of which support
continued reliability improvement.

155 North 400 West | Suite 200 | Salt Lake City, Utah 84103
www.wecc.org

WECC-0142
•

Assist in the development of regional reliability assessments that are
conducted on a regional, interregional, and interconnection-wide basis.

Lead Engineer, RAPA “Reliability Assessment and Performance Analysis”
(2010-Present)
•

Managed the seasonal, long-term and special assessments to examine
current and future adequacy and operational reliability of the Southwest
Power Pool Region Bulk Power System.

•

Coordinator for GADS, TADS, DADS (2011-2015)

Lead Engineer, Compliance Auditor (2008-2010)
•

Audit bulk power system owners, operators, and users operating within
the SPP Region to verify the findings of compliance

•

Performed compliance investigations with NERC concerning system events

Southwest Power Pool (2006-2008), Little Rock, AR 72205
Senior Operations Trainer (2007-2008)
•

Train new System Operators and Operation Engineers. Created the OIT
Program (Operator in Training), and developed training materials for
Southwest Power Pool’s “System Operator Conference”.

•

Assist Operation Engineers with improvements to simulator models;
conduct restoration training and control center back up drills; perform job
task analysis, and develop and present training classes to meet FERC
requirements.

Senior Tariff Administrator ITO (2006-2007)
•

Assist with development of a new Independent Transmission Operations
(ITO) department. Extract and analyze department requirements from the
Open Access Transmission Tariff (OATT), create and deliver training to
Market participants on the OATT, and write policies and procedures for
the ITO department.

•

Validate, evaluate and respond to Transmission Service Requests and
Electronic Tags in accordance with the OATT.

Vectren Energy (1999-2006), Evansville, IN 47702
Transmission Operations Engineer/ NERC Compliance Coordinator/
Training Coordinator (2003-2006)

2

WECC-0142
•

Engineer responsibilities include performing power flow studies,
transmission outage coordination and providing other technical support to
operations personnel during normal and emergency operations.

•

NERC Compliance Administrator for the Transmission System Operations
Department.

•

Administrator for Vectren Energy in 2005. Responsible for creating policy
and implementing changes to bring Vectren into compliance with NERC
standards.

•

Developed, organized and wrote Vectren’s Emergency Black Start
Procedures. Also created and wrote procedures for generator reactive
testing.

•

Transmission System Operations Training Coordinator duties included
initiation and design of the annual training program for operations
personnel.

Transmission System Operator (1999-2003)
•

Responsible for monitoring and controlling the electric grid for Southern
Indiana.

•

Duties include monitoring system parameters such as voltage, current,
power, equipment status, etc. and to react to and solve problems
appropriately.

•

Prepare for and issue instructions for switching equipment, and directing
maintenance personnel during emergency situations.
American Electric Power (1987-1999), Rockport, IN 47635

Supervisor / Plant Engineer (1988-1999)
•

Manage major generator plant projects in excess of 10 million dollars.

•

Responsible for overseeing a team of electricians.

•

Perform equipment efficiency tests on pumps, cooling towers, coal mills,
unit heat rate, etc.

•

Design new equipment such as coal waste water drainage, dust collector
controls, sampling systems, etc.

•

Work with production teams to identify and repair problems. Conduct
training programs for electricians.

Relay Technician (1987-1988)

3

WECC-0142
•

Relay Technician for Rockport Plant start up. Responsibilities included
inspecting drawings; checking newly installed cables, wiring; redesigning
and rewiring newly installed controls.

•

Experienced with 600 volt and larger breakers’ switch gear, protective
relays and large motors.

Century Communications (1982-1984)
Owensboro, KY 42301
Assistant Chief Engineer (1982-1984)
Responsible for maintaining equipment performance, FCC performance tests,

•

repairing equipment such as large transmitters, microwave equipment,
receivers, audio equipment, and video equipment.
Academic, Education & Professional Certification
Bachelor of Science Degree, Electrical Engineering; Western Kentucky

•

University, Bowling Green, Kentucky
Associate of Science, Industrial Technology; IVY Tech State College,

•

Evansville, Indiana
Technical Certificate, Electronic Communications; Kentucky State College,

•

Owensboro, Kentucky
Professional Development
Electric System Operator
•

NERC Reliability Authority Certification, Evansville, IN

•

Continual training (60-70 Hrs/year) to maintain NERC Reliability
Authority Certification

Engineering/Technical
•

Certified Hydraulic Technician, Fluid Power Society.

•

PLC training, Design Data, Columbus, Ohio

•

Hydraulic and pneumatic training, Dravo Wellman, Pittsburgh, PA

•

ABB Generator Excitation training, Charleston WV.

•

Voltage Stability, General Electric, Indianapolis, IN

4

WECC-0142
Bart McManus 1

Mr. McManus is an electrical engineer in the Operational Controls group at the

Bonneville

Bonneville Power Administration (BPA). His core work relates to Balancing
Authority management and Contingency Reserves. He has been providing

Power

solid, functional solutions to Contingency Reserve issues for the last 25 years.

Administration

•

Mr. McManus’ experience also includes:

• Member of the first BAL-002-WECC Drafting Team
• Member of the WECC Resources Subcommittee that created the original
BAL-002 Disturbance Control Standard.

• As one of BPA’s BAL-002 and BAL-002-WECC subject matter experts,
Mr. McManus ensures reliability compliance for BPA by providing expert
analysis, keeping current with industry trends, and participating in
Standards Development activities.

• Represents BPA the NWPP Reserve Sharing Group (RSG), which is
responsible for compliance of BAL-002 and BAL-002-WECC for its 32 BA
member entities.

• Coordinates across multiple technical groups to consolidate BPA’s
agency experience in Balancing Authority management, Contingency
Reserves.
Mr. McManus hold a Bachelor of Science in Electrical Engineering from the
University of Washington (1993).
ChaRee

Mrs. DiFabio has been with the Northwest Power Pool (NWPP) since 2000.

DiFabio,

She is currently the Reserve Sharing Group (RSG) Committee Manager and has

Northwest

held this position since 2013. She manages all activities related to the NWPP

Power Pool

RSG Committee and in addition, manages the NWPP Reserve Sharing
Program which includes, program documentation updates to conform with
industry requirements and applicable standards (WECC & NERC BAL-002),
implementation of new BAs into the NWPP RSG, Reserve Sharing Training,
and is responsible for reporting and compliance documentation as related to
BAL-002.

Jessica Kelsey
Arizona Public
Service (APS)

As a Load Serving Entity (LSE) energy trader responsible for procuring
reserves associated with BAL-002-WECC-3, Contingency Reserve, Ms. Kelsey
brings a unique perspective to the team.
Ms. Kelsey has worked in the electric industry since 2013. During that time,
she has served as a real-time energy trader, program manager for APS’s

1

WSC approved December 8, 2020.

5

WECC-0142
entrance into the Energy Imbalance Market, and as supervisor of the real-time
energy trading team (2018-2020). In these roles Ms. Kelsey has been
responsible for the planning and procurement of contingency reserves hour-tohour and intra-hour keeping APS in compliance with NERC and WECC
standards.
Kevin Conway
Western Power
Pool 2
Michael
Pfeister
Salt River
Project 3

Mr. Conway is a senior level utility operations executive with over 35 years of
experience in multi-faceted fields of power generation, transmission
operations, power management, information technology, engineering, system
maintenance, physical and cyber security measures, industrial safety,
administration and NERC compliance.
Mr. Pfeister currently serves as Manager of Grid Operations for Salt River
Project (SRP), Scottsdale, AZ (March 2019 – Present) where he is responsible
for: 1) the safe and reliable operation of the SRP power delivery system, 2)
managing frontline Automatic Generation Control and real-time Power
Distribution Operations, 3) managing six Grid Operations Shift Supervisors
and operations staff comprised of 24 operators, 4) ensuring a culture of
compliance.
Mr. Pfeister’ s experience includes:
Manager, Grid Operations Support
SRP, – May 2018 – March 2019
Responsible for the frontline support of AGC and PDO real time operations.
Manage support staff comprised of 4 System Operators and 4 support
Engineers. Efforts include SRP implementation of the Energy Imbalance
Market, selection of RC, support of the Operator Training Simulator, process
improvements, interfacing with many different departments within SRP, BA
and energy market representatives throughout the WECC, and the Reliability
Coordinator.

Manager, Balancing Area Operations
SRP, – June 2015 – May 2018

2
3

WSC approved May 2024.
WSC approved December 8, 2020.

6

WECC-0142
Responsible for the safe, reliable operation of the SRP Balancing Area (BA)
within the bounds of over 100 NERC requirements. Manage BA staff
comprised of 13 System Operators and one support Engineer.
Supervisor, Scheduling and Reliability Services
SRP – May 2008 – June 2015
Managed SRP long term transmission sales per the SRP OATT. Supervised
day-ahead scheduling and After-the-fact reconciliation personnel and OASIS
transmission outage scheduling function. Served as TGO Duty Supervisor.
Voting member of the WECC Interchange Scheduling and Accounting
Subcommittee, Chair of WECC Real Time Scheduling Work Group, and served
as chair of several WECC regional criterion drafting teams. Support TGO in
various WestConnect initiatives and in NERC compliance.
Supervisor, TGO Training
SRP– March 2005-May 2008
Developed and administered training programs for certification of TGO
System Operators and to meet departmental needs. Monitored for changing
NERC and WECC training requirements and adjusted as necessary including
the transition from NERC exams to the use of continuing education hours for
credential maintenance.
System Operator
SRP– March 1997 – March 2005
Power Plant Operator
SRP – October 1988 – March 1997
Mr. Pfeister holds a Bachelor of Science degree in Management from the
Western International University. He is a member/contributor to various
WECC committees and their subgroups.
Rick Hydzik

Mr. Hydzik currently serves at Avista Corp where he is responsible for System

Avista Corp 4

Operations procedures and compliance related to BAL-002 and BAL-002WECC (16 years).
Mr. Hydzik’ s experience also includes:

4

WSC approved December 8, 2020.

7

WECC-0142
•

Responsibility for Avista's participation and interaction with the
Northwest Power Pool (NWPP) Reserve Sharing Group, including data
collection and analysis

•

Chair of the NWPP Reserve Sharing Group Committee

•

Background in System Protection (10years) and System Planning (3
years)

•

Participation on several NERC and WECC drafting teams

•

Chair of various WECC INT drafting teams and presently serving as
vice Chair of NERC BAL-003 standard drafting team.

Christopher

Christopher McLean has worked as a technical subject matter expert at the

Mclean

California Energy Commission since late 2008. Mr. McLean earned a Bachelor
of Science degree in Mathematics and Actuarial Science in 1999 at Oregon State
University and has been plying his craft in the energy sector ever since. From
private sector consulting, to managing portfolios of CRRs, along with many
and varied public sector collaborations, Mr. McLean brings more than twenty
years of power systems modeling experience to the energy sector discussion.
Professional Experience
Electric Transmission Systems Program Specialist, California Energy
Commission; 2009 –
⦁ Policy focused assessments of production cost modeling, power flow
modeling and

other systems modeling approaches brought to various forums at the CAISO,
CPUC and
WECC; support of the Energy Commission’s data collection and integration
processes for
obtaining and analyzing system data from the CAISO and WECC;
advancement of the
Energy Commission’s utilization of GIS analytics in long term system
planning.
CRR Portfolio Manager, CES Ltd.; 2008
⦁ Developed strategic, multi‐million dollar, Congestion Revenue Rights
hedging instrument

portfolios for several clients participating in the CAISO CRRMarkets.

8

WECC-0142
Energy Analyst, California Electricity Oversight Board; 2006 – 2008, 2003 ‐ 2004
⦁ Maintained the EOB market monitoring function, supplied data analytics and
market

rules analyses in support of EOB litigation of California Energy Crisis cases
before the
FERC.
1
Market Monitoring Specialist – Ancillary Services, California Independent
System Operator,
2004 – 2006
⦁ Market Monitor responsible for multiple time‐frame assessments of four
CAISO markets

for ancillary services; operated and maintained the CAISO production cost
modeling
platform supporting the development of the Transmission Economic
Assessment
Methodology, expert witness at CPUC proceeding.
Staff Consultant, Henwood Energy Services, 1999 – 2003
⦁ Conduct regional wholesale market simulations with production cost models
supporting

Project Finance assessments in all NERC regions; contributions to the
development of
novel wholesale market risk analytics software.
Education
Oregon State University: B. Sci. Mathematics, 1999

9